Update: Centers for Medicare and Medicaid Services (“CMS”) issued the Contract Year 2024 Proposed R

Where do you see that?
And what do you mean by approach? I hold educational workshops that people rsvp for themselves. I don’t approach them. The form they fill out to rsvp says and agent will contact them.

After the seminar I hand out an optional survey that says a licensed agent will contact them.

If none of that is allowed then I guess DM marketing won’t be allowed either.


You can’t hand out a scope of appointment or business reply card at educational events to contact the client proposed for 2024.I’ve seen several discussions on this and the interpretation is you can’t contact anyone .They must contact you. I’m positive your rsvp they fill out to attend the seminar with written language allowing you to contact them later is not compliant . So your saying you contact people that come to seminar that express no interest at the seminar to be contacted?Supposedly all leads developed by a lead vendor wether direct mail,Facebook or any social media will be against the rules .
 
You can’t hand out a scope of appointment or business reply card at educational events to contact the client proposed for 2024.I’ve seen several discussions on this and the interpretation is you can’t contact anyone .They must contact you. I’m positive your rsvp they fill out to attend the seminar with written language allowing you to contact them later is not compliant . So you’re saying you contact people that come to seminar that express no interest at the seminar to be contacted?Supposedly all leads developed by a lead vendor wether direct mail,Facebook or any social media will be against the rules .

Incorrect. He can have people RSVP with name, phone and how many attending. They can CURRENTLY have a consent to contact card and business card at the event. They cannot force anyone to complete it, not can they require a registration form. They can also have a sales event/appointment immediately following that educational event.

what is proposed: Is lead cards that are purchased will not be compliant. Sales events immediately following educational no go. Cross selling is 48 hours after appointment. Scope of appointment needs to be 48 hours out. The call recording which is now required for all sales and service is being proposed to be dialed back to only application process.
 
You can’t hand out a scope of appointment or business reply card at educational events to contact the client proposed for 2024.I’ve seen several discussions on this and the interpretation is you can’t contact anyone .They must contact you. I’m positive your rsvp they fill out to attend the seminar with written language allowing you to contact them later is not compliant . So your saying you contact people that come to seminar that express no interest at the seminar to be contacted?Supposedly all leads developed by a lead vendor wether direct mail,Facebook or any social media will be against the rules .

You are well out of your lane, dude.
 
Incorrect. He can have people RSVP with name, phone and how many attending. They can CURRENTLY have a consent to contact card and business card at the event. They cannot force anyone to complete it, not can they require a registration form. They can also have a sales event/appointment immediately following that educational event.

what is proposed: Is lead cards that are purchased will not be compliant. Sales events immediately following educational no go. Cross selling is 48 hours after appointment. Scope of appointment needs to be 48 hours out. The call recording which is now required for all sales and service is being proposed to be dialed back to only application process.


So your saying currently if they fill a rsvp card out and send it in that gives an agent authorization to call that person 3 weeks later? Its considered a ptc form even though they filled nothing out at the seminar . Correct on the other things you mentioned . As far a lead cards I’ll simply have all leads sent back to me even though i use a vendor to mail. I’ll exclusively run ways i can help them apply for extra help and Medicaid .Zero to do with mapd. As far as t-65 it will all be geared toward med sups. I’m 100% face to face so little of this affects me .
 
Incorrect. He can have people RSVP with name, phone and how many attending. They can CURRENTLY have a consent to contact card and business card at the event. They cannot force anyone to complete it, not can they require a registration form. They can also have a sales event/appointment immediately following that educational event.

what is proposed: Is lead cards that are purchased will not be compliant. Sales events immediately following educational no go. Cross selling is 48 hours after appointment. Scope of appointment needs to be 48 hours out. The call recording which is now required for all sales and service is being proposed to be dialed back to only application process.

He’s not incorrect. The proposed rules do NOT allow SOA or BRC to be collected at Educational Events for 2024. It’s explicitly stated in the proposal.
 
I see they took recording your client conversations away which was ridiculous. I know agents sending app links from Medicare center to clients to avoid recording. Send the link and the client fills everything out . So no soa needed . Many agents guide them as they fill out .

Have you ever looked at the consumer signature on an electronic SOA via sunfire? It's not a "real signature" easily manipulated.

In any case, a verbal SOA is all one needs anymore.
 
In any case, a verbal SOA is all one needs anymore.

Where are you getting this info? If working over the phone and it's required that you record all calls in the "Sales Cycle" how could you explain based on what is being suggested that you receive an inbound transfer and enroll an hour later? The removal of the "when possible" or similar jargon seems to eliminate that loop hole. Serious question.
 
Another thing their proposing is no soa’s or any ptc forms at educational events .

Ok all of you compliance gurus. I held an educational event today and promised the guy I would call him back to help him apply for the Medicare savings program. If this happens next year, would I be out of compliance with the new rules if eventually he becomes my client.
 
Ok all of you compliance gurus. I held an educational event today and promised the guy I would call him back to help him apply for the Medicare savings program. If this happens next year, would I be out of compliance with the new rules if eventually he becomes my client.

I would say no as the helping someone with msp is not selling him anything . But that’s like saying i door knock someone for fe and he asks me about Medicare and I sell him . It’s all a grey area .
 
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