Medicare Lead Compliance

atlantainsguy

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I thought this post would be helpful for anyone interested in creating their own Medicare leads. Just keep the message absolutely generic, and you should be as close to bulletproof as you can get today.

CMS clarified how and why generic leads are exempt from filing and approval in a March 30, 2009 memorandum on page 89 under the subhead “Multiple Organization Marketing Pieces Created by Agents”.

“Under certain circumstances agents/brokers that create customized materials will not be required to submit to the MAO or PDP sponsor for CMS review. Essentially, materials that are generic in nature and do not discuss content specific to plan benefits, cost sharing or include plan names will not require review and approval. Generic materials may reference the different product types (e.g., MA plan, MA-PD, Cost Plan, PDPs) offered by the agent.”

atlantainsguy
 
I thought this post would be helpful for anyone interested in creating their own Medicare leads. Just keep the message absolutely generic, and you should be as close to bulletproof as you can get today.


CMS clarified how and why generic leads are exempt from filing and approval in a March 30, 2009 memorandum on page 89 under the subhead “Multiple Organization Marketing Pieces Created by Agents”.

“Under certain circumstances agents/brokers that create customized materials will not be required to submit to the MAO or PDP sponsor for CMS review. Essentially, materials that are generic in nature and do not discuss content specific to plan benefits, cost sharing or include plan names will not require review and approval. Generic materials may reference the different product types (e.g., MA plan, MA-PD, Cost Plan, PDPs) offered by the agent.”


atlantainsguy



So I would think this would apply to (i.e)G. Gordon's "Medicare Supplement Savings" ad or "New MedSUpp Plans" right?
 
You must be completely "generic" and deal with Medicare conceptually. When you mention the words "Med Supp" you are now subject to State DOI regulation. I would not do that.

Instead, keep things so "open-ended" that either MS or MA could apply, and try to get closer to MA if possible -- even if you never intend to sell a single Med Advantage plan.

Here are a couple of generic concepts that should help illustrate how to take advantage of this CMS "loophole":

1. Are you getting all the Medicare benefits you're entitled to?

2. Congress recently passed new Medicare legislation. You need to know how this affects you.

atlantainsguy
 
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