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CMS updated Scope of Appointment (SOA) guidance in the 2018 Medicare Marketing Guidelines (MMG). The new MMG regulations go into effect with 2018 marketing materials (i.e., October 1).
- SOAs are required for any one-on-one, face-to-face appointment held outside of an educational event or formal marketing/sales event
- All SOAs can now be signed prior to the start of your previously scheduled appointment
- Obtaining the SOA 48 hours in advance of an appointment is no longer a requirement
- All SOA guidelines remain in place
Be prepared to answer client questions regarding the upcoming changes to the Medicare ID Card. Beginning April 2018, new Medicare ID cards without social security numbers will be sent to beneficiaries. Through December 2019, providers will be allowed to use either the old HICN or the new identifier. All cards will be replaced by April 2019.
New cards will use a unique randomly assigned combination of letters and numbers that will be referred to as the Medicare Beneficiary Identifier (MBI). The MBI will be an eleven character code so it can easily be distinguished from the nine-digit social security number.
When discussing the change, remind clients that they should not discard the red, white and blue Medicare card until the transition period ends December 2019.
CMS has confirmed a renewed focus on all websites, especially those that market to consumers with the intent to collect contact information to be used or distributed as a lead. CMS has found “numerous and troubling violations on third-party websites”.
When developing or updating your website, pay special attention to the more common violations:
- Needs assessments or inappropriate request for health status (i.e., weight, tobacco use)
- Identifying a Medicare Supplement Insurance Plan as a Medicare Advantage Plan
- Using unsubstantiated absolute superlatives (i.e., the best, the biggest)
- Absence of required disclaimers
Websites must be clear and easy to navigate, maintain a separate and distinct section for Medicare information, and be submitted to a carrier for CMS approval.
- Must be advertised as educational
- Hosted in a public venue by the Plan/Part D sponsor or an outside entity
- May answer beneficiary initiated questions
- May set up a future marketing appointment and distribute business cards and contact information for beneficiaries to initiate contact
- Must not include marketing or sales activities or distribution of marketing materials or enrollment forms
- May not conduct a marketing/sales event immediately following an educational event in the same general location (e.g., same hotel)