Now that Medicare Advantage plans, FMOs, and other Third-Party Marketing Organizations (TPMOs) have had a chance to review the 2024 Final Rule, their work begins. Here are Rebellis Group’s Top 5 takeaways for Sales and Marketing teams.
Marketing must be local. National advertising describing benefits that do not exist in most counties is prohibited. If advertising benefits, they must be offered in the county where the marketing is placed or airing, and the plans that offer them must be listed. CMS is very specific about this. MA plans should review materials this AEP from their FMOs/TPMOs and should opt out of marketing that is not aligned with CMS’s new guidelines.
The Scope of Appointment (SOA) is making a big comeback this AEP. There MUST be 48 hours between the SOA and an in-person meeting. There are only two exceptions to this rule:
The last 4 days of an election period.
Note: MA Plans and FMOs are going to have to put in new education and monitoring to make sure this rule is being followed.
Sales oversight is a priority. This should be a priority in the next three months before AEP begins. If the plan currently has one, they should make sure it is robust with reporting and monitoring - not just policies and procedures. CMS is clearly putting the responsibility on MA Plans to oversee their external sales channels and their marketing tactics and consistently monitor and improve results.
Changing the requirement for recording calls is great news. CMS has altered their wording around the recording of calls and will require marketing, sales, and enrollment calls and web-based technology such as online meetings to be recorded. This is a relief that normal business calls and in-person meetings do not have to be recorded.
Lead sharing is not on the chopping block…yet! CMS did not act on the proposed change regarding sharing personal beneficiary information (i.e., leads). This came as a big relief to TPMOs, although it is possible CMS could still issue new guidance prior to AEP.
As always, Rebellis Group is happy to discuss any of these or other regulations.