Three Compliance-Minded Steps to Take for 2018 Marketing and Sales

Is it me, or is time flying by? Applications are done, bids are in, new plans are in planning stages, and existing plans are getting ready for the launch of the next benefit year.

The 2018 model materials were released late last month, and any second now, we should see the release of the 2018 Medicare Marketing Guidelines (MMG). The industry is expecting additional Summary of Benefits guidance to be incorporated in the MMG by the Centers for Medicare & Medicaid Services (CMS) as my colleague Diane Hollie noted in her article on the CMS Spring Conference. We are also interested to see if any modifications are made to CMS’ draft MMG language on Additional Marketing Fees as discussed in this article. Time will tell!

What is the compliance professional to do to help sales and marketing professionals prepare while we are in this holding pattern for the finalized guidance? Three things:

  1. Evaluate what worked and what didn’t work well in the material review process last year. Did you conduct a lessons learned session at the end of the season? Any top performers that contributed to the success of last year’s material creation, review, and submission activities? If you did not have a chance to do a lessons learned session, take some time to reflect this week. This way, you can set expectations with your team and colleagues.
  2. Identify greatest risks and rewards in sales and marketing activities, and take proactive steps to correct. We all understand the obligation to conduct a risk assessment. As Carrie Barker-Settles told an engaged audience at this year’s Gorman Health Group Forum, it is important to understand both the risks and rewards of each sales channel. Did your organization have an upswing in marketing misrepresentation complaints? What sort of turnover did the prospective member call center experience over the past year? Ongoing review of potential risks of non-compliance and fraud, waste, and abuse is necessary to help drive continued customization to monitoring and auditing plans.
  3. Develop training tools and checklists. If these are not in place already at your organization, these resources are integral to helping marketing and sales stay in between the lines.

Does this quick hit list warrant additional discussion within your team? If you are doing the above already, fantastic! As a good friend so alliteratively once told me, proper prior planning prevents poor performance. That said, are you inundated with the day-to-day of CMS requests, six+ hours of meetings a day, and little time to catch up on what new guidance was released? Do you need temporary help during the material review season? At anytime of the year when things go wrong, we often see it become an “us vs. them” situation between Operations and Compliance; it’s demoralizing and unproductive, and we don’t like to see anyone in that situation.

Contact me directly at for more information on how we can help.


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Regan Pennypacker
Regan Pennypacker

Regan is Senior Vice President of Compliance Solutions at Gorman Health Group (GHG). She leads the Compliance Solutions practice, responsible for multidisciplinary projects such as Part C and Part D audits, new applications, marketing material reviews, risk assessments, and training engagements. As a member of this team, she has provided compliance direction and insight on industry best practices to many GHG clients. Regan brings GHG clients 19 years of experience in the healthcare industry. Read more

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