Top 10 Changes – Draft Medicare Communications and Marketing Guidelines

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:

  1. 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.
  2. 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.
  3. 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.
  4. 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.
  5. 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.
  6. CMS clarifies that sales lines at organizations are not required to follow the customer service call center hours of operations requirements.
  7. The “health and wellness information” mailing statement has been removed from guidance.
  8. 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.
  9. 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.
  10. 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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Diane Hollie
Diane Hollie

Diane Hollie Associate Vice President, Sales, Marketing & Strategy Diane Hollie is Associate Vice President of Sales, Marketing & Strategy at Convey Health Solutions (Convey). In this role, she provides strategic consulting services to ensure organizations maximize their sales distribution and marketing mix. Diane brings Convey clients more than 20 years of experience in marketing, sales, and product development for Government programs. Her strong marketing, sales and compliance background has extended to providing compliance guidance for marketing, sales and customer service communications. Since joining Convey, Diane has worked with numerous clients to meet and exceed their enrollment goals, maximize their market potential with strong competitive products and develop marketing and sales strategies to improve market share within the ever-changing Centers for Medicare & Medicaid Services (CMS) compliance guidelines. Many of Convey’s clients have turned to Diane to provide marketing analysis, marketing and sales plan development and operational assessments of marketing, and marketing compliance and sales areas. She is fluent in developing the working tools and training programs for future success within the market and with CMS. Diane has published several articles providing marketing and sales guidance within the Medicare Advantage market.

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