Your preparations for the 2010 annual enrollment period (AEP) should, by now, be in full swing. This year’s AEP may prove to be one of the most active since 2005-06, as more and more boomers reach qualifying age. In order to be at the top of your game, you need to have as many marketing materials as possible ready to go at a moment’s notice.
In the past, that might have been easy — draw something up, send it through compliance, and mail it out. But with the Centers for Medicare and Medicaid Services’ (CMS) recently approved changes to the marketing regulations, getting your advertising materials approved might take a little more work than usual. The following step-by-step guide will help ease the marketing development process with CMS. It will be important to have all your marketing materials ready as soon as possible to maximize your sales potential — it’s going to be a busy year.
Know the rules
CMS has issued a draft version of Medicare Marketing Guidelines, dated May 15, 2009, for the first time since July 2006. Become familiar with these guidelines. They include all of the new regulations from the Medicare Improvements for Patients and Providers Act (MIPPA), and additional guidance from CMS. The final version of the Medicare Marketing Guidelines is scheduled to be released soon.
Familiarizing yourself with the CMS Medicare Marketing Guidelines will help prepare your team for training before the AEP begins. The CMS Medicare Marketing Guidelines have incorporated many of the dos and don’ts of selling Medicare Advantage products. The guidelines provide all the information needed to help ensure that your marketing materials are compliant.
Develop standardized language
Believe it or not, there will be more new disclaimers to add to your marketing materials this year. The following are just a few examples of disclaimers and requirements to be aware of to keep your marketing materials compliant with the latest CMS regulations.
- You must include the plan type (e.g., HMO, PPO, PFFS, etc.) using CMS standard terminology. You will need to display the plan name and the plan type in this standard format on all of your marketing materials, including general advertising materials.
- If an agent’s phone number is included in marketing materials, then the plan sponsor’s customer service phone number must also be included. The materials should clearly indicate that calling the number will direct them to a licensed insurance agent and that calling the customer service number will allow them to obtain plan information or to enroll. All requirements in the marketing guidelines related to the customer service phone number must be met (e.g., listing the hours of operation).
- General advertising materials that provide basic benefit information to generate a response — such as including copayment amounts, monthly premium amounts, or mentioning specific coverage types — must include the following disclaimer: “The benefit information provided is not comprehensive. Additional information should be requested before making a decision about your coverage.”
- Review the latest CMS marketing guidelines in detail to make sure you have included all requirements and disclaimers, new and old. The best way to do this is to develop a best-practices document of all approved disclaimers for your organization with an explanation for how each should be used. Use this document as your checklist. In addition to the disclaimers and requirements, you may also want to standardize other descriptive marketing copy, such as health plan company descriptions and benefit descriptions. This way, once the copy is approved, you don’t have to worry.
Save time and prevent errors: Use templates and carets
Use templates when developing marketing materials, as they can cut down on the number of variations you need to develop. “Template material” is any marketing material that includes placeholders for variable data to be filled in at a later time. Using template materials allows you to develop one master document rather than submitting a new document for approval each time the variable data is changed. Examples of variable elements include date and location information for sales presentations or benefits that may vary between plans, including cost sharing, premiums, and health plan names.
It is important to show CMS how the placeholders will be filled in by inserting the name of the field within carets (e.g., <date>), or filling in the placeholder fields with all the variables within the carets (e.g., <$10.00 copay/$15.00 copay>). Template materials will have only one marketing identification number, regardless of the number and combination of variable elements.
Although these tips provide a good primer, this is just the beginning. Make sure that you have carefully reviewed the advertising section of the CMS guidelines to guarantee that your materials will be approved on the first review. Following these steps can help ensure a smooth transition into the 2010 selling season.
Diane Hollie is a senior consultant at Gorman Health Group, a national Medicare advisory firm providing health plans technology solutions and consulting services. She can be reached at 215-499-1417 or [email protected].