Am I bound by the CMS guidelines if the "clients" I'm telemarketing to are
Facility owner\operators where the senior prospects live\play? I don't have any names of the seniors, only names and tel#s of the facility owners\operators. My plan is to call these owner\operators and try to set an appointment to visit their facility to introduce some Medicare products (MAdvantage plans, etc) and see if any of their senior residents may qualify\benefit. Senior doesn't have to be present as I sense these owner\operators have a very detailed understanding of their seniors' health situation. I'd like to bring a brief 1-page flyer highlighting the benefits of the Medicare product which is CMS approved to this initial appointment with the operator, but "modify" the flyer by only putting my tel# on it for contact purposes and no reference to the
HMO organization name nor to CMS approval. After the owner\operator has read that brief flyer and seems ready to allow a presentation in front of the group, I'd then contact the
HMO directly so they could make a presentation\bring enrollment apps. Basically, my function\role seems to be that of a "referring broker". Thus, am I ok to create my own
MA flyer if the intended audience is a facility operator, and not the senior enrollee?
Medicare Marketing Guidelines
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