how often are medicare communications and marketing guidelines updated

how often are medicare communications and marketing guidelines updated插图

What are the updated Medicare communications and marketing guidelines (MCMG)?

On February 9th, 2022, CMS provided an updated Medicare Communications and Marketing Guidelines (MCMG) document for Medicare Advantage (MA) plans, section 1876 cost plans, and Medicare Prescription Drug Plans.

When does CMS consider a health plan a communication?

If it doesn’t meet both standards, CMS considers it a communication. For example, the Evidence of Coverage (EOC) may have content that would meet the definition of marketing, but its intent is to advise beneficiaries about their benefits, not to convince them to enroll in the health plan. Therefore, CMS would consider it a communication.

What are the marketing guidelines for Medicare Advantage?

The Marketing guidelines reflect CMS’ interpretation of the marketing requirements and related provisions of the Medicare Advantage and Medicare Prescription Drug Benefit rules (Chapter 42 of the Code of Federal Regulations, Parts 422 and 423).

Are You using the new CMS guidelines memo in conjunction?

Keep in mind that the new guidelines memo is to be used in conjunction with the 2019 guidelines as CMS will not be providing a full document this year. Do you know what constitutes marketing and communications under the guidelines?

What is a pre-enrollment checklist?

Pre-enrollment checklists fall under the communications definition and must be provided to potential beneficiaries with the Summary of Benefits (SB) when the SB accompanies an enrollment form. Plans/Part D sponsors may remove portions of the checklist that aren’t applicable to a plan type or product.

What is a presentation slide CMS?

The presentation slides also include a peek into other changes under consideration at CMS. The agency is in the process of updating the Health Plan Management System marketing submission codes. CMS also plans to conduct retrospective reviews to monitor compliance with the new requirements. These reviews may include requests to submit marketing and communications materials.

What is marketing intent?

In a PowerPoint presentation, Reinhard and Willard explained that marketing’s intent is to draw attention to a plan or plans and influence an enrollment decision, including retention. Marketing’s content includes information about the plan’s benefit structure, cost sharing and measuring or ranking standards. However, it excludes materials that may include the content, but do not meet the definition of “intent.”

What is communications in healthcare?

Communications refers to all materials and activities that provide information to current and prospective enrollees. Marketing is now considered a subset of communications. But CMS tweaked the definition to focus on materials and activities meant to influence a beneficiary’s decision about their healthcare coverage.

When is the CMS fall conference?

The Centers for Medicare & Medicaid Services (CMS) discussed its updated communications and marketing guidelines during its annual Medicare Advantage and Prescription Drug Plan fall conference on Sept. 6. In this article, we look at the most notable changes.

Can you change the disclaimer language in Medicare?

Although you may not change disclaimer language, CMS will allow Plans/Part D sponsors to include additional language before or after the disclaimer to clarify how a disclaimer applies to different products. In the Medicare Communications and Marketing Guidelines, CMS gives the following example: “When selecting an HMO product, remember that except in emergency or urgent situations, we do not cover services by out-of-network providers who are not listed in the provider directory." This disclaimer wouldn’t apply to a stand-alone Part D plan.

Is EOC a communication?

To meet the new definition of marketing, the material or activity must meet both the intent and content requirements. If it doesn’t meet both standards, CMS considers it a communication. For example, the Evidence of Coverage (EOC) may have content that would meet the definition of marketing, but its intent is to advise beneficiaries about their benefits, not to convince them to enroll in the health plan. Therefore, CMS would consider it a communication.

What does CMS mean when it says "if a potential enrollee provides permission to be contacted, the contact?

CMS deleted the phrase: “If a potential enrollee provides permission to be contacted, the contact must be event-specific and may not be treated as open-ended permission for future contacts.” Now that this phrase is gone from the guidelines, it appears that if a potential enrollee grants permission to be contacted, that same permission can be used during different election periods. With CMS removing the phrase, the door is open to more extended permission to contact those eligible for Medicare.

What is a communication letter?

An example of communications is a letter sent to enrollees by a specific plan to remind them to get their flu shot. The intent of the letter is not to steer the reader into making a plan selection or to stay with the plan, but rather to encourage existing enrollees to get a flu shot. The letter contains factual information about coverage and was provided only to current enrollees.

What is included in CMS marketing?

Excluded are materials that may meet the definition of marketing based on content, but don’t meet the intent requirements of marketing.

What is marketing in health insurance?

Marketing is defined as “a subset of communications and includes activities and use of materials by the Plan/Part D sponsor with the intent to draw a beneficiary’s attention to a plan or plans and to influence a beneficiary’s decision-making process when selecting a plan for enrollment or deciding to stay enrolled in a plan.” CMS states that marketing contains information about the plan’s benefit structure, cost-sharing, measuring, or ranking standards.

What constitutes marketing and communications under the guidelines?

Do you know what constitutes marketing and communications under the guidelines? CMS refers to communications as “activities and use of materials to provide information to current and prospective enrollees.” This means that all activities and materials aimed at prospective and current enrollees, including their caregivers and other decision-makers, are communications within the scope of the regulations.

What is the new word for SMC scripts?

That included those to be used by agents or brokers. The word “script” has been replaced by “talking points,” which indicates that the agents can now deliver a more improvised and interactive presentation.

When will the MCMG be updated?

Before long, the MCMG will be updated for 2021. Look for those updates as early as July but most likely in early September 2020. Find the full list here .

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