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Before we dive in, it's crucial not to solely depend on these key points, as they are only a portion of the overall impact. We strongly advise reviewing the regulation and guidance thoroughly in order to gain a comprehensive understanding of each requirement and the potential changes you may need to implement. Also, be sure to visit https://yourfmo.com/cms-faqs which is frequently updated as we receive guidance from CMS and our carrier partners. Sales and Marketing Activities
- Visiting a beneficiary without an appointment is always prohibited, even when the beneficiary has expressed an interest in MA products.
- You may no longer set up future personal marketing appointments or have beneficiaries complete Scope of Appointment forms at educational events.
- Marketing events are prohibited from taking place within 12 hours of an educational event in the same location. The same location is defined as the entire building or adjacent buildings.
- You must wait 48 hours between the completion of the Scope of Appointment and the start of the personal marketing appointment except when:
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- SOAs are completed during the last four days of a valid election period.
- Unscheduled in-person meetings (walk-ins) are initiated by the beneficiary.
- Note: CMS has indicated that this 48-hour period is not required for inbound calls from enrollees. At this time, unless CMS provides further clarification, this requirement applies to outbound calls.
- The pre-enrollment checklist (PECL) must be provided prior to enrollment, including telephonic enrollments. "Effect of current coverage" has been added to the PECL.
- TPMOs must provide the number of plans and products it offers, as well as SHIP contact information in its disclaimer. TPMOs who offer all plans and products must also provide a version of this disclaimer.
- TPMOs must record all marketing, sales, and enrollment calls, including the audio portion of calls via web-based technology, in their entirety. Other types of calls have been excluded.
Marketing Materials
- Authorized TPMOs must submit multi-plan materials to HPMS after pre-review by MA organizations.
- The use of superlatives such as "best" or "most" is prohibited unless specific criteria for supporting documentation are fulfilled.
- Do not use the Medicare name and CMS logo in a misleading way. Use of the Medicare ID card image must be authorized for use by CMS.
- The MA organization name or marketing name(s) as listed in HPMS must be identified in the marketing of any products, plans, benefits or costs.
- Marketing communications may not include information regarding potential savings that are based on a comparison of typical expenses borne by uninsured individuals, unpaid costs of dually eligible beneficiaries, or other unrealized costs of a Medicare beneficiary.
For Agent Use Only. |