- 484
There are 24 days left, during the comment period anyone can comment and let CMS know what they think about these proposed rules. So far there are only 35 comments! With the number of members on this forum we could really have our voices heard if everyone goes and posts a comment about the removal of "when practicable" from the 48hr rule. Imagine if it went from 35 comments to several hundred in a matter of days, all comments against the removal of "when practicable" for the 48hr soa. They might just listen!
Go make your voices heard! Comment at the following link, its super easy! [EXTERNAL LINK] - Regulations.gov
Here is the comment I posted.
"Re: CMS Proposed Rule 48hr scope of appointment changes
It is important to consider that well meaning regulation may actually have a negative impact on the Medicare beneficiaries CMS is trying to protect.
Seniors can, shop for a mortgage, purchase a car, make investment and insurance decisions without a requirment that they wait 48hrs before receiving information from their advisor. Yet when they turn 65 suddenly they are infantilized and are told that they can not receive information on their Medicare Part C and Part D coverage options until 48hrs have passed from the date of their request.
48hrs will pass and eventually they will be sitting accros from that agent or back on the phone with them and they are no safer at that point then they were 48hrs ago. Therefore, the 48hr SOA requirment is entirely ineffective at protecting seniors. All it does is make it even more difficult for them to get the information they need to make an educated coverage decision.
In the proposed rule it is stated that "The reasons for why a meeting must occur within the 48 hour timeframe are numerous and subjective, meaning what is practicable for one person may not be practicable for another,". This statement is entirely true, and it is also exactly the reason " When practicable" should be included in the final rule. By removing "when practicable " you eliminate the ability of the benficiary to make the choice on thier own about when and where they would like to receive that information. This only serves to add an additional obstacle that the beneficiary must deal with before receiving guidance and information.
There is no other financial product in existence that requires a 48hr cooling off period before even talking about the product. The 48hr SOA requirement does nothing to protect medicare benficiaries becuase ultimately the 48hrs will pass and they will be right back with that same agent and nothing will have changed from 48hrs prior. Because of this, the 48hr requirment does not actually protect medicare beneficiaries in any meaningful way. It only creates another obstacle on their path to suitable Part C and D coverage.
Go make your voices heard! Comment at the following link, its super easy! [EXTERNAL LINK] - Regulations.gov
Here is the comment I posted.
"Re: CMS Proposed Rule 48hr scope of appointment changes
It is important to consider that well meaning regulation may actually have a negative impact on the Medicare beneficiaries CMS is trying to protect.
Seniors can, shop for a mortgage, purchase a car, make investment and insurance decisions without a requirment that they wait 48hrs before receiving information from their advisor. Yet when they turn 65 suddenly they are infantilized and are told that they can not receive information on their Medicare Part C and Part D coverage options until 48hrs have passed from the date of their request.
48hrs will pass and eventually they will be sitting accros from that agent or back on the phone with them and they are no safer at that point then they were 48hrs ago. Therefore, the 48hr SOA requirment is entirely ineffective at protecting seniors. All it does is make it even more difficult for them to get the information they need to make an educated coverage decision.
In the proposed rule it is stated that "The reasons for why a meeting must occur within the 48 hour timeframe are numerous and subjective, meaning what is practicable for one person may not be practicable for another,". This statement is entirely true, and it is also exactly the reason " When practicable" should be included in the final rule. By removing "when practicable " you eliminate the ability of the benficiary to make the choice on thier own about when and where they would like to receive that information. This only serves to add an additional obstacle that the beneficiary must deal with before receiving guidance and information.
There is no other financial product in existence that requires a 48hr cooling off period before even talking about the product. The 48hr SOA requirement does nothing to protect medicare benficiaries becuase ultimately the 48hrs will pass and they will be right back with that same agent and nothing will have changed from 48hrs prior. Because of this, the 48hr requirment does not actually protect medicare beneficiaries in any meaningful way. It only creates another obstacle on their path to suitable Part C and D coverage.
