By Lauren Flynn Kelly
CMS’s newly updated Medicare Communications and Marketing Guidelines (MCMG) contain multiple flexibilities that were previously unavailable to plan sponsors. These include a loosening of rules around co-branding, educational events and marketing of rewards and incentives programs (RI programs), as well as the ability to operate a call center dedicated to prospective enrollees.
Although CMS at press time hadn’t posted a redlined version of the complete 2020 document, an Aug. 6 memorandum from the CMS Medicare Drug & Health Plan Contract Administration Group highlighted the various updates, including the deletions from 2019, and urged plans to cross-reference the memo with the existing MCMG.
“The deletions are more important than the insertions,” says Michael Adelberg, a principal with Faegre Baker Daniels Consulting and a former top CMS MA official. “Probably the most important deletion concerns the prohibition on holding back-to-back educational and marketing events. This seems to open the door to piggybacking marketing sessions on educational events.”
Last year’s MCMG expanded what can happen at educational events by allowing plan representatives to set up future marketing appointments and hand out business cards and contact information for beneficiaries to initiate communications. But by deleting the word “future” and the stipulation that representatives “may not conduct a marketing/sales event immediately following an educational event in the same general location,” it appears that CMS may allow plans to set up marketing appointments immediately after an educational event, says Kelli Back, a health care attorney in Washington, D.C.
Another example of important “deletions” is around RI programs, for which marketing no longer has to be done “in conjunction with information about plan benefits,” nor does it have to include information about all RI programs offered by the MA plan.