Addressing Key Questions on the 2018 Medicare Marketing Guidelines

We had a fantastic turnout for our webinar last week on the 2018 Medicare Marketing Guidelines (MMG). Something I’ll reiterate is that the MMG are for everyone. Nilsa Rudisill and I had plenty of spirited discussions when working to narrow down the content to fit in a single hour. We know your time is valuable, and we appreciate everyone’s attendance.

Some great questions were received that Nilsa and I thought would be beneficial to share in case others in the industry are contemplating similar themes. Some of our clients even shared their responses from the Centers for Medicare & Medicaid Services (CMS). While we cannot share those specific responses, it does confirm to us there are ambiguities in certain sections, and the agency is responding in a timely manner. Therefore, if you are in doubt, reach out!

  • Let’s address the sample Summary of Benefits (SB), a key document for beneficiaries. By no means is the sample a “model” document in the same vein as CMS releases model Evidence of Coverage documents. Most readers already have their SBs under development, which is great.
  • A few questions came in pertinent to the submission of events to CMS in the Health Plan Management System (HPMS). When does the change take place? The guidance applies to 2018 activities. Unless CMS says otherwise, continue to submit events pertinent to the 2017 plan year.
  • Does the change in HPMS submission of events signal a change in surveillance activities? From the outside looking in, the answer is yes. CMS used the information submitted by sponsors to select events for surveillance. A change in the agency’s direct monitoring activities should not change your own internal monitoring and auditing, unless, that is, you already know you need to step it up.
  • How should Scopes of Appointment (SOAs) now be tracked? Nothing much has changed. The documentation may be in writing in the form of a signed agreement by the beneficiary or a recorded oral agreement. Any technology (e.g., conference calls, fax machines, designated recording line, pre-paid envelopes, and email) can be used to document the SOA. Remember, you must document the scope of the appointment prior to the appointment. Be prepared to demonstrate this in your documentation. 

As we’ve stated before, you’ve got to wonder if each revised chapter CMS issues is a collection of lessons learned from the previous period of time. Regardless, the agency seems to be streamlining and refining guidance not only to ease burden on sponsors but to also provide necessary clarification as needed. What changes are impacting your organization and to what extent? Contact us on ways we can help your operations be successful in implementing the MMG.

 

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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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