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A Step-by-step Guide to Ensuring CMS Approves Your Marketing Materials

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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].

Tips for Developing Strong Ads — In Spite of All the Regulations

CMS regulations have you stuck in a creative rut? The following tips can help you build a marketing campaign that effectively builds brand awareness and generates qualified leads.

Concept or themes
Not all health plans or general agencies mean everything to everyone. What differentiates you in the market? Develop marketing concepts and themes to incorporate into all of your creative pieces. Repeating your message and design elements will help to develop your brand, build recognition in the marketplace, and generate response.

Audience identification
You may only have 30 seconds to get your message noticed. Help ensure the audience is listening. Call out to your audience in your first creative element. Tell the audience that the message is for Medicare beneficiaries living in a particular county or state. This information attracts attention and can cut down on the number of unqualified leads.

What’s in it for me?
In every direct mail lead-generation kit or marketing piece, always repeat your most important messages. Why do members enroll in your health plan? (You need to know this answer.) Make sure your prospects know the benefits of enrolling in your health plan(s). And, since prospects are not typically reading or listening to advertising messages with their full attention, be sure to repeat the most important message.

Photos: How old should you go?
Your audience may be younger than you think. Or, they may perceive themselves to be younger than they actually are. Using photos that depict Medicare beneficiaries who appear very old may miss your target market altogether.

Call to action
A strong call to action should be included as a part of all marketing and advertising materials in order to generate response. Use a call to action in at least one headline, within the copy, and on the back panels of brochures. Envelopes also provide great opportunities to use a call to action. Remind the prospect that they need to do something.

P.S. One more time: What’s in it for me, and act now
When developing direct mail lead-generation kits, self mailers, or enrollment packages, it is important to insert a postscript at the close of a letter. Quickly restate the value proposition and use call-to-action copy.

The P.S. is one of the most-read portions of any letter. Do not write a letter without it.