Thank you to all who came to the Gorman Health Group (GHG) webinar regarding the 2019 Centers for Medicare & Medicaid Services (CMS) Medicare Communications and Marketing Guidelines (MCMG). We had a great attendance and are working to answer all of your questions and get a Q&A to all who attended plus the presentation! We wanted to take a minute to discuss a few items where GHG received a large number of questions: mailing statement disclaimers, Open Enrollment Period (OEP) beneficiary plan changes, and website review.
There are now only two mailing statements in Appendix 2 of the Disclaimers. The first is for Plan Information, and this is causing the most confusion. The disclaimer states the required text is “Important [Insert Plan Name] Information”. GHG interprets this to mean this disclaimer only needs to be on your member’s important plan information such as enrollment, benefit, operations, and other important plan information. GHG does not believe CMS intends advertising mailings to use this disclaimer as it would be confusing and misleading to prospects.
In addition, GHG contacted CMS about the requirement to insert the plan name since there was confusion about whether the plan needed to utilize the plan benefit package (PBP) plan name vs. the Medicare Advantage Organization (MAO) name and whether this was even necessary since the name of the plan is already on the envelope. GHG’s interpretation of CMS’ response is that as long as the name of the MAO is on the envelope and is recognizable to the member as their health plan, then inserting the plan name is not needed.
There was some confusion regarding the plan types a beneficiary can select during the OEP. A beneficiary is allowed a one-time change. The following chart describes the allowed changes:
- Medicare Advantage Prescription Drug plan (MA-PD) to MA-PD
- MA-PD to MA-only plan
- MA-only to MA-PD plan
- MA-only plan to MA-only plan
- MA-PD to Original Medicare (with or without Part D)
- MA-only plan to Original Medicare (with or without Part D)
Website = New Guidance From CMS That Will Make You Smile!
Those in Original Medicare or Original Medicare with Part D are not able to enroll in an MA-only or MA-PD plan. In addition, the OEP is not available for those enrolled in Medicare Savings Accounts, Cost plans, or Program of All-Inclusive Care for the Elderly (PACE) plans.
On Friday, May 10, CMS released an email blast, “Updates to the Website Requirements in the Medicare Communications and Marketing Guidelines.” CMS is no longer requiring website marketing content to be submitted into the Health Plan Management System (HPMS) for a 45-day review. Plans can now submit their websites via HPMS as a Word document that contains a URL (sound familiar?). Screenshots, test sites, etc., are not needed. Plans are permitted to submit the website as File & Use – both their own and/or third party websites. This means all websites must be submitted five days before going live, so mark your calendar! In addition, CMS added guidance about the Material ID and websites. All website pages must have a Marketing ID, but the ID does not need to include “M” or “C.”
When making website updates, the plan must include the website’s URL in a Word document and include a summary of the changes. The updates may go live five days after HPMS submission. Plans do not need to take down their website while making updates, but make sure the changes do not go live until five days after the HPMS submission.
CMS has stated another version of the 2019 MCMG will be released before the end of the summer. I am hoping for more clarifications to occur. Let us know how we can help you!
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