Types of Calls in Pay Per Call – defined in simple terms.
Whether you are new to pay-per-call or a grizzled veteran, I hope you’ll appreciate this clarification of some commonly misused industry vernacular.
Recently, we have received an interesting, ill-informed response to the notion of a verified inbound call. So, I’m taking a minute to set the record straight. Call Verified Inbounds are not to be lumped in with outbound generated warm transfers. If these share space in your mind, you are missing a huge opportunity. They should and are a compliance dream, but your compliance department needs to be informed.
Warm Transfers or Live Transfers have become synonymous with “Outbound Dialing.” And Outbound Dialing has become associated with bad actors – often offshore, who have no regard for TCPA regulations, thereby causing TCPA issues for the buyers of these calls. Due to the vicarious liability clause in the TCPA, if your brand engages with a third party to drive calls, your brand is liable for any black hat tactics the third party may employ. There are many examples of TCPA Class Actions that tend to get certified pretty easily – for reference, check TCPAworld.com, which does a good job discussing active cases and lending colors.
The advantage to warm transfers is that there is a more personal touch. If compliant, this can be an effective tool. However, the disadvantages often outweigh the advantages due to outbound risk.
Direct Inbounds or Consumer Initiated Inbounds. This means a consumer initiated phone call. A consumer has seen an ad online (or offline) and has called a number to get more information, a free quote, etc. Inbounds are not without risk. But typically, the violations are more around the FTC and not the FCC – and in the case of Medicare, CMS. Meaning, the compliance violations occur more around misleading, incomplete or false information – which do not carry the same vicarious liability risk. There has been a huge shift from “warm transfers” to “Inbounds” over the last few years.
For the Medicare Industry, inbounds have become vital, because there is a 48 hour rule in place for outbound contact. Inbounds are considered by most “walk-ins” which gives the agent the ability to do the scope of appointment and write the policy more quickly.
But inbounds are tricky. You should know where and how these calls are being generated. For example, if a consumer calls a number that they received in a text message, that is actually an outbound call in the eyes of the law. Meaning, the Telephone Consumer Protection act applies. It doesn’t matter if the consumer placed the call – the number that was in the text message got there through an outbound mechanism.
The other issue with inbounds is that someone can sneak outbound calls onto these lines. We’ve seen numerous brokers state a campaign has a forbidden live hand-off and instead do a “cold drop.” Meaning, don’t let the buyer know there was an outbound dial that was part of the plan. Sometimes there is a legitimate reason – but this is definitely an eyebrow raiser.
And inbounds are happening without any tried and true way to know in absolute terms that there were no nefarious tactics used.
There are tools out there that help you become more compliant – but they do have limitations. One such tool is TrueCall which can verify if a consumer called from a web landing page – ensuring at least that the customer placed the call had seen the ad and experience promised by the publisher.
Call Verified Inbounds.
These are the bomb-diggity. The best of both worlds. Call Verified Inbounds are as the name indicates; consumer initiated calls that are answered by a live call center agent, qualified, and then transferred with a warm handoff. These solve most of the issues with the other types of calls. Because these are not warm-transfers (outbound), there is little TCPA concern. In the event a bad actor sends an outbound call through this line, call center agents are trained to root these non-inbounds out and report/DNC etc.
Specifically for Medicare, these are the absolute best. They prevent agents from having to weed through often-confused callers. And they are walk-ins which represent actionable opportunity.
We think Verified Inbounds are the “Cadillac of Calls” for your organization. They limit your exposure, and improve the overall quality of the call. They also represent a more positive consumer experience. If your job is to maximize opportunity while reducing risk, this is a product worth trying.
Please submit your information here, if you’d like to discuss how eQuoto can help you maximize your inbound call strategy.
