Headquarters address: 14524 Golden Harbor Lane, Winter Garden, Florida 34787, United States
Year established: 2023
Company type: Professional association
Membership: 40+ member organizations
Expertise: Medicare and health insurance, Affordable Care Act (ACA)
Key people: William DeCourcy (president); Shaun Greene (co-founder, secretary, and board member); Mark Seghers (co-founder, board member emeritus)
The Insurance Marketing Coalition Limited (IMC) is a non-profit professional association aimed at promoting ethical and compliant marketing practices in the health insurance industry. Its members include insurance companies, advertising and marketing organizations, and technology firms.
The IMC and its members are committed to educating Americans and helping them make informed decisions when it comes to healthcare and Medicare coverage.
The IMC was launched in November 2023 during the National Association of Insurance Commissioners’ (NAIC) Fall National Meeting in Orlando, Florida. Its goal was to align lead generators with industry best practices and regulatory compliance.
The organization was founded by Mark Seghers, chief executive and co-founder of Inspire Health Tech, and Shaun Greene, principal at Hoplite Insurance Services. Both remain with the coalition as board members.
In a LinkedIn post, Seghers revealed that the proposed changes by the Centers for Medicare & Medicaid Services (CMS) on how Medicare is sold and marketed prompted the IMC’s formation. He added that the organization had the backing of about 30 Medicare leaders and with their help, it would ensure “the ethical and lawful generation and handling of insurance leads.”
The IMC aims to ensure that marketing efforts within the Medicare and health insurance sector are transparent and legally compliant. Marketing activities must also prioritize the consumers’ best interests. On its website, the organization lists some of its contributions to the industry:
in 2022 alone, the IMC enrolled more than a million beneficiaries in Medicare Advantage plans, giving many senior-aged Americans access to comprehensive health plans
advertising and marketing member firms help connect beneficiaries with insurance agents and brokers, who, in turn, provide them with personalized guidance in finding the right coverage
member tech firms give insurance agents, brokers, and marketers access to digital platforms and other support services to make the insurance-buying process more transparent and efficient
IMC members help educate consumers about the benefits of having health coverage through various media and speaking engagements
All members must adhere to a set of standards of conduct that the Insurance Marketing Coalition has put in place. Here’s a summary of IMC’s code of conduct. You can access the complete document on the organization’s website.
Members must comply with federal and state marketing and advertising laws, especially when it comes to false advertising, including:
Members must keep abreast of regulatory changes through continuing education
IMC members must ensure that consumers have given their consent to being contacted; consumers who request to not be contacted must be added to a “do not contact” list unless they ask to be contacted again
Members must ensure marketing and sales activities are accurate and transparent
Members must maintain the confidentiality of consumer information and IMC documents and discussions
Members are responsible for cultivating a diverse and inclusive culture within the IMC
Members must conduct themselves with a high level of professionalism
Members must ensure that data sharing and handling are secure and compliant with federal and state regulations
Members must not sell leads older than 90 days from when consent was taken unless stated in the agreement
For leads older than 30 days, IMC members must ensure that the contact number is still active
Members are required to use third-party technology to make sure online consent records are accurate
Members are responsible for conducting due diligence with whom they do business with using the Insurance Marketing Coalition Standards Appendix A (Know Your Partner) at the least
Members must have a process for tracking third-party advertising compliance and investigating questionable third-party advertisements
Members must provide continuous training on ethical practices and regulatory compliance to all employees; these sessions must be documented and the results monitored
Members must keep accurate records of all IMC activities; these records must be organized for easy access during internal audits and regulatory inspections
Members must aim for excellence in all IMC initiatives and activities
Members must foster a culture of collaboration and teamwork by sharing their knowledge and expertise
Members of the Insurance Marketing Coalition must be present in at least 80 percent of scheduled meetings; they can assign a representative if they can’t attend
Members can offer constructive feedback on how the IMC can improve its processes
The IMC’s Standards Committee is responsible for investigating any reported violation of its Code of Conduct. The members involved are also given seven days to address the allegations in writing.
Once the investigation is done, the Standards Committee makes recommendations to the board of directors on the possible next steps. The board then assesses the committee’s findings. If a violation is confirmed, the board decides on the penalties and communicates the decision back to the Standards Committee.
Here are the possible sanctions:
first finding: notification of the board’s decision and reminder of the penalties for future violations
second finding: suspension of up to three months
third finding: one-year suspension
fourth finding: permanent expulsion from the Insurance Marketing Coalition
Suspended members are stripped of the following privileges:
They will also be listed as such on the IMC website.
Regardless of whether a violation is found or not, members must correct any reported issues within seven days of their written response. They must also inform the Standards Committee once the issue has been resolved.
IMC membership comprises various industry players whose goal is to promote effective insurance marketing strategies through ethical and legal practices. These include:
insurance carriers: also called insurance companies or insurers, these firms provide financial coverage in an insurance policy
insurance agencies and insurance brokerages: businesses that connect consumers with insurance companies
marketing and advertising companies: firms that help insurance companies reach potential customers through various insurance ad campaigns
technology firms: companies that provide platforms, services, and tools for the insurance industry to make processes more efficient; these include some of the top insurtech companies in the US
lead generators: businesses that focus on identifying and nurturing potential insurance customers
The Insurance Marketing Coalition doesn’t provide a list of members on its website. Membership, however, isn’t strictly confidential. Organizations can choose to publicly disclose their IMC membership. Some known members of the coalition include:
Affordable Benefit Choices: an insurance agency specializing in affordable health and health-related benefits
AmerLife: an independent marketing organization that offers insurance and retirement products for seniors
Benepath: a provider of self-generated leads to insurance agents and agencies
CarynHealth: a cloud technology solutions and managed services provider for organizations that offer health benefit plans
Inspire Health Tech: a healthcare technology solutions provider, specializing in making Medicare plan recommendations
Lendmarx: a fintech firm that provides financial vertical marketplaces on behalf of advertisers, affiliates, and call centers
QuinStreet: an online marketplace that allows businesses to connect with potential clients
Taalk.ai: a conversational platform that lets businesses automate interactions with customers through AI-powered agents
Companies can join the Insurance Marketing Coalition through annual and quarterly memberships. The fees are $3,500 and $950, respectively. Regardless of the membership type, companies can:
New members are also featured on IMC’s Member Profile Spotlight.
William DeCourcy is the inaugural president of the Insurance Marketing Coalition. He also serves as chairman of the board. DeCourcy is a performance marketing and insights executive with decades of experience in various industries, including insurance, banking, utilities, and hospitality.
DeCourcy gets support from the other members of the IMC’s leadership team, which include:
Rachel Honoway, vice-president
Shaun Greene, secretary, co-founder
Chris Michelson, membership committee chair
Clelland Green, board treasurer
Caitlyn Edwards, director of business development
Farzin A. Espahani, communications committee chair
Rebecca McDavid, standards committee chair
Mark Seghers, board member emeritus, co-founder
The IMC was in the news recently because of a case it brought against the Federal Communications Commission (FCC). The case centered on the conditions on how companies get permission before making robocalls.
Insurance Marketing Coalition Ltd. v. FCC, et al., No. 24-10277 (Eleventh Circuit) involved the TCPA, which says that companies must get “prior express consent” before robocalling a potential customer. In 2012, the FCC required that permission be in writing for marketing or sales calls.
In 2023, the FCC added new restrictions to what “consent” means:
customers can only give consent to one company at a time
the subject of the calls must be “logically and topically” related to the interaction that led the customer to give consent – this means that if a client clicked “yes” to get health insurance quotes, they shouldn’t get calls about unrelated products like car insurance deals
The IMC believed that the new rules went too far. The coalition argued that the FCC didn’t have the legal authority to change what “consent” means. It also said that the commission was overreaching by adding conditions that the original law didn’t require.
In the end, the court sided with the IMC. The court ruled that “prior express consent” should be taken in its usual meaning – that someone clearly agreed ahead of time to be contacted. It also said that the FCC’s new rules changed the basic meaning too much. Because of this, the court cancelled the FCC’s additional requirements.
The IMC’s webinar about the court decision can be viewed on its website.
