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October 01, 2015 at 09:40 AM
Right now, it looks as if Hurricane Joaquin could make my local radio weather reports (not to mention the condition of my cellar) a lot more interesting Monday and Tuesday next week.
Of course, state and federal rules put tough restrictions on what kinds of coupons, hats, t-shirts, mugs or other items insurance markets can use to get prospects’ attention.
The Medicare Advantage and Medicare Part D prescription drug programs and the HealthCare.gov public exchange system have strict rules on the “nominal gifts” used in promotional activities. America’s Health Insurance Plans (AHIP) notes in a Medicare marketing educational guide that the maximum value of a gift must be $15 or less; that the combined value of gifts provided to one individual must be $15 or less; and the marketers must try to limit the total value of the gifts any one individual receives in a year to $50 or less.
The U.S. Department of Health and Human Services (HHS) forbids HealthCare.gov agents and Web brokers from using “rebates and giveaways” to attract qualified health plan (QHP) buyers.
Here’s a suggestion: Create a list of emergency supplies that federal disaster preparedness officials want Americans to have. Exempt the supplies that are clearly mainly for emergency use from federal health program marketing promotional item restrictions. Let health carriers, agents, brokers and other marketers have their own marketing budgets set the caps on the value of disaster-prep-related novelty items.
If, for example, a Patient Protection and Affordable Care Act (PPACA) public exchange, a PPACA public exchange “enrollment facilitator,” a PPACA exchange-registered agent, or a Web broker wants to use flashlights, first-aid kits, whistles, “blankets in a pouch,” or similar items to reel in business, then let it put a sample of the giveaway in a cardboard box. Let the box of disaster-prep novelty items be all the documentation the marketer needs to show government auditors that its giveaways were fine.
On the one hand, the reality is that consumers will probably end up using the novelty items for non-emergency purposes. Big health program marketing giveaway efforts could also crowd out sales of some types of emergency supplies through ordinary retailers. If the government and retailers see giveaways doing serious damage to retail sales of flashlights and the like, everyone involved needs to reconvene to figure out ways to keep the emergency supplies on retail store shelves.
