The New MCMG and What You Need to Know
In February, CMS published an update to the Medicare Communication and Marketing Guidelines, the document that provides baseline guidance for the marketing of Medicare Advantage and Part D plans. It not only lays out a good deal of technical guidance for what Plan Sponsors must have on their websites and in their marketing materials but also governs what agents in the field may do to reach beneficiaries.
This recent update represents the first major change to the MCMG since 2019. In this update, CMS has provided clarity on several matters and adjusted a few previous guidelines. Much of this applies to plan sponsors and their administrative activities, but a few key points do impact agents!
Here are the three big things you need to know.
Changes to Marketing Material Submissions
Last summer, CMS announced some changes to marketing material submissions, allowing for the first time materials to be submitted by third parties. In the behemoth initial section of this update, CMS clarifies standards and processes for submitting marketing materials to the Health Plan Management System for review and Opt-in by plans. This includes third-party Multi-plan marketing materials, like those created by agents and lead vendors. In addition, it outlines the plan sponsor, and consultant processes for approval of these materials.
Most agents and agencies do not have direct access to HPMS to submit marketing materials, but your upline may. We at Senior Marketing Specialists are happy to assist contracted agents with the submission process when needed and review any marketing materials you are considering using. While creating your own marketing materials can be worthwhile, this process generally takes up to 45 days, so please plan ahead!
Clarification on Nominal Gifts to Consumers
A vital clarification regarding the meaning of “cash equivalents” was contained in this update. While it has long been known that Nominal gifts (less than $15 per occurrence/$75 per year) are permitted under certain guidelines, there was a sense of haziness over whether gift cards were strictly prohibited. CMS has now clarified that general gift cards (e.g. VISA gift card), or those to retailers offering a wide variety of goods (Amazon, Walmart, etc.) are prohibited. However, this clarification opens the door to gifts cards that are acceptable, such as those to limited or specialty retailers and service providers, such as a Starbucks card or gas card.
This clarification provides agents with a fantastic opportunity to partner with many local businesses to offer gift cards for their goods and services. If you plan to do a drawing or raffle style prize, you can even consider larger amounts based on the size of the event. A gentle word of caution however that the total value of gifts, including snacks and beverages, counts toward the $15 per person limit.
Various Updates for Plan Documentation Requirements
The remainder of the updates largely covered various plan sponsor responsibilities and materials they are required to have available via website. Also included were provisions on translation of certain documents, announcing new or ongoing provider affiliations, and a copy of the standardized pre-enrollment checklist.
All in all, this update to the MCMG provides clarity and new strategies for agents while also supporting the overarching theme of increased oversight that we have seen since last fall. Paired with the CY 2023 MA and PDP Proposed rule, it represents what may become the most comprehensive increase in oversight since the advent of the Scope of Appointment. Luckily there are clear solutions and opportunities for agents to use these changes to build a more effective and trusted business.
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