Centers for Medicare & Medicaid Services (CMS) has released the draft Medicare Communications and Marketing Guidelines (MCMG) for 2020. Of the CMS draft MCMG changes, here’s our top 10:
- Plans must include a toll-free TTY number when a telesales number is listed in the same font size as the other phone numbers. This requirement no longer applies to the customer service number only. Plans must ensure that all materials include this update moving forward.
- Plans/Part D sponsors are now required to submit via the Health Plan Management System (HPMS) hold time messages that include benefit information or promote the plan.
- The Centers for Medicare & Medicaid Services (CMS) clarifies that plans must submit their website annually, must include a material ID for the current year on all web pages, and subsequent website submissions with updated marketing content must include a note on where to find those changes on the website along with the summary of changes.
- Administrative payments to field marketing organizations (FMOs) can continue to be based on enrollment, provided payments are at or below fair market value (FMV). When impracticable, administrative payments made to agents/brokers, such as mileage and materials, may also be based on enrollment. However, CMS expects organizations to pay actual expenses when possible. Payment structures must be determined prior to a plan year and remain in effect throughout that plan year. Plans must make payment structures available to CMS upon request.
- Document changes:
- Annual Notice of Change (ANOC), Evidence of Coverage (EOC), and formulary erratas may be provided electronically if the enrollee has opted in to receiving electronic versions.
- If an enrollee has requested a hard copy directory, the plan may attach an addendum of recent updates instead of printing an entirely new document if the request is made prior to the annual update. CMS does not expect a hard copy directory or addendum to be sent whenever there is a change to the directory.
- Plans must not indicate effective or term dates in the provider directory if a provider is listed prior to the effective date or is confirmed to leave the network.
- CMS clarifies that sales lines at organizations are not required to follow the customer service call center hours of operations requirements.
- The “health and wellness information” mailing statement has been removed from guidance.
- The plan Online Enrollment Center Disclaimer “Medicare beneficiaries may also enroll in <plan name> through the CMS Medicare Online Enrollment Center located at http://www.medicare.gov” has been removed for 2020.
- The disclaimer “This information is not a complete description of benefits. Call [insert customer service phone number/TTY] for more information” has been removed for 2020.
- The federal contracting statement is no longer required on communications that are not marketing. The federal contracting statement is only required on marketing materials.
There are several other changes being suggested – this is just our top ten list. Plus, all draft changes continue to be subject to further change until the final MCMG are released.
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