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Reply to 2018 CMS Marketing Guidelines     
Old 07-25-2017, 01:35 PM   #11
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2018 CMS Marketing Guidelines Re: 2018 CMS Marketing Guidelines
I found this one a bit interesting:

*********************
70.4.1 – Educational and Marketing Events
42 CFR 422.2268, 423.2268, 422.504(f)(2), 423.505(f)(2)
Plans/Part D Sponsors are not required to upload educational, formal and/or
informal marketing/sales events in HPMS. Plans/Part D Sponsors must keep
accurate records of all marketing/sales and educational events, and CMS
reserves the right to request event information at any time.
*********************

I suppose the reporting requirements proffered by plan sponsors will still be on the "strict" side.
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  Reply With Quote to 2018 CMS Marketing Guidelines
Old 07-25-2017, 04:30 PM   #12
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craig_ritter on 2018 CMS Marketing Guidelines
 
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2018 CMS Marketing Guidelines Re: 2018 CMS Marketing Guidelines
No 48 hour rule for Scope of Appointment. YUGE!
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  Reply With Quote to 2018 CMS Marketing Guidelines
Old 07-25-2017, 05:41 PM   #13
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2018 CMS Marketing Guidelines Re: 2018 CMS Marketing Guidelines
Originally Posted by Justin Bilyj View Post
That's awesome! I bet you hear controlled demolitions alot. I heard a guy died there a couple of weeks ago...
Yep. It was a stunt man. He missed the landing pad.
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  Reply With Quote to 2018 CMS Marketing Guidelines
Old 07-26-2017, 08:28 AM   #14
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2018 CMS Marketing Guidelines Re: 2018 CMS Marketing Guidelines
Question Has anyone paid a referal fee to a non liscensed person for a MAPD PLan? Section 120.4 does not explicitly say you can or can not.It does say you can pay an agent 100 dollars

120.4 - Compensation Applicability and Definitions
42 CFR 422.2274, 423.2274

Referral/Finderís Fees: Referral/Finderís fees paid to agents and brokers, including independent, employed, and captive agents and brokers, may not exceed $100 ($25 for PDPs). CMS expects that this amount will not provide enough financial incentive for an agent or broker to recommend or enroll a beneficiary into a plan that is not the most appropriate for the beneficiaryís needs.
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  Reply With Quote to 2018 CMS Marketing Guidelines
Old 07-26-2017, 08:46 AM   #15
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2018 CMS Marketing Guidelines Re: 2018 CMS Marketing Guidelines
Originally Posted by craig_ritter View Post
No 48 hour rule for Scope of Appointment. YUGE!
Am I missing something? Are you saying the 48 hour rule is no more? I just went back and looked at the AHIP material and it still shows it as a requirement.
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Old 07-26-2017, 09:34 AM   #16
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2018 CMS Marketing Guidelines Re: 2018 CMS Marketing Guidelines
Has anyone paid a referal fee to a non liscensed person for a MAPD PLan?
Paying for a referral is fine if not contingent on a sale. I believe the IRS and possibly your state DOI takes issue with referral fees in xs of $25

------------------------------------
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GA Medicare Supplement Rates
(404) 252-5859
  Reply With Quote to 2018 CMS Marketing Guidelines
Old 07-26-2017, 11:15 AM   #17
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2018 CMS Marketing Guidelines Re: 2018 CMS Marketing Guidelines
Originally Posted by sman View Post
Am I missing something? Are you saying the 48 hour rule is no more? I just went back and looked at the AHIP material and it still shows it as a requirement.
Yes, you don't need to get an SOA 48 hours in advance. The 2018 MMG says you need to get it in advance of making a presentation, which we interpret as being immediately before the presentation, IE, same day SOA.

It's a bit clearer what I mean if you look at the 2017 and 2018 MMG side by side (section 70.4.3).

We're talking to a lot of the carriers about it and, eventually, they will clarify, but from the way this reads, if you have permission to contact (like a client), you can call them, schedule an appointment for 8am the next morning, show up at their house, have them sign an SOA right then, present a new plan and enroll them.

For Medicareful, you can call a client, have them do an SOA electronically, present the plan over the phone and have them enroll electronically ALL IN ONE PHONE CALL.

I think this is pretty big news. Maybe it's just not out there yet?!?

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Originally Posted by sman View Post
Am I missing something? Are you saying the 48 hour rule is no more? I just went back and looked at the AHIP material and it still shows it as a requirement.
It's probably not in the AHIP training because the 2018 MMG came out on July 20th which is after the AHIP training was developed. Typically, the MMG comes out around the first week in June, it was about a month and a half late this year.

I am going to blog on all the agent relevant changes later today. I think there are about 15-20 things agents need to know. Also, as the carriers digest the MMG, a consensus will develop around what everything means. We might interpret things one way and a carrier sees it differently, but generally, it crystallizes into a pretty uniform standard.

For example, I'm also trying to get clarification on some requirements around CMS approval of BRC's. The wording seems a bit contradictory. We may be able to use generic BRC's again for permission to contact and with the same day SOA, that might make direct mail cost effective again. Not 100% sure on that.

------------------------------------
Craig Ritter, VP
Ritter Insurance Marketing

www.ritterim.com
www.medicarequoteengine.com

Last edited by craig_ritter; 07-26-2017 at 11:08 AM. Reason: TYPO
  Reply With Quote to 2018 CMS Marketing Guidelines
Old 07-26-2017, 11:17 AM   #18
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Todd King on 2018 CMS Marketing Guidelines
 
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2018 CMS Marketing Guidelines Re: 2018 CMS Marketing Guidelines
Originally Posted by craig_ritter View Post
Yes, you don't need to get an SOA 48 hours in advance. The 2018 MMG says you need to get it in advance of making a presentation, which we interpret as being immediately before the presentation, IE, same day SOA.

It's a bit clearer what I mean if you look at the 2017 and 2018 MMG side by side (section 70.4.3).

We're talking to a lot of the carriers about it and, eventually, they will clarify, but from the way this reads, if you have permission to contact (like a client), you can call them, schedule an appointment for 8am the next morning, show up at their house, have them sign an SOA right then, present a new plan and enroll them.

For Medicareful, you can call a client, have them do an SOA electronically, present the plan over the phone and have them enroll electronically ALL IN ONE PHONE CALL.

I think this is pretty big news. Maybe it's just not out there yet?!?

----------



It's probably not in the AHIP training because the 2018 MMG came out on July 20th which is after the AHIP training was developed. Typically, the MMG comes out around the first week in June, it was about a month and a half late this year.

I am going to blog on all the agent relevant changes later today. I think there are about 15-20 things agents need to know. Also, as the carriers digest the MMG, a consensus will develop around what everything means. We might interpret things one way and a carrier sees it differently, but generally, it crystallizes into a pretty uniform standard.

For example, I'm also trying to get clarification on some requirements around CMS approval of BRC's. The wording seems a bit contradictory. We may be able to use generic BRC's again for permission to contact and with the same day SOA, that might make direct mail cost effective again. Not 100% sure on that.
As big of a change as that is, you would think we would hear about it by now though. You're correct though, it's Yuge!
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  Reply With Quote to 2018 CMS Marketing Guidelines
Old 07-26-2017, 11:21 AM   #19
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2018 CMS Marketing Guidelines Re: 2018 CMS Marketing Guidelines
Originally Posted by Todd King View Post
As big of a change as that is, you would think we would hear about it by now though. You're correct though, it's Yuge!
Just to make it easier, here is a "side by side" of 2017 and 2018:

2017:
When conducting marketing activities, in-person or telephonically, a
Plan/Part D Sponsor may not market any health care related product during
a marketing appointment beyond the scope that the beneficiary agreed
before the meeting with that individual. The Plan/Part D Sponsor must
document the scope of the agreement 48 hours prior to the appointment,
when practicable. Distinct lines of plan business include MA, PDP and Cost
Plan products. If a Plan/Part D Sponsor would like to discuss additional
products during the appointment in which the beneficiary indicated interest,
but did not agree to discuss in advance, the Plan/Part D Sponsor must
document a second scope of appointment (SOA) for the additional product
type to continue the appointment.

2018:
When conducting marketing activities, in-person or telephonically, a
Plan/Part D Sponsor may not market any health care related product during
a marketing appointment beyond the scope that the beneficiary agreed to
before the meeting. The Plan/Part D Sponsor must document the scope of
the appointment prior to the appointment. Distinct lines of plan business
include MA, PDP and Cost Plan products. If a Plan/Part D Sponsor would like
to discuss additional products during the appointment in which the
beneficiary indicated interest, but did not agree to discuss in advance, the
Plan/Part D Sponsor must document a second scope of appointment (SOA)
for the additional product type to continue the appointment.
------------------------------------
  Reply With Quote to 2018 CMS Marketing Guidelines
Old 07-26-2017, 12:44 PM   #20
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2018 CMS Marketing Guidelines Re: 2018 CMS Marketing Guidelines
Originally Posted by craig_ritter View Post
Yes, you don't need to get an SOA 48 hours in advance. The 2018 MMG says you need to get it in advance of making a presentation, which we interpret as being immediately before the presentation, IE, same day SOA.

It's a bit clearer what I mean if you look at the 2017 and 2018 MMG side by side (section 70.4.3).

We're talking to a lot of the carriers about it and, eventually, they will clarify, but from the way this reads, if you have permission to contact (like a client), you can call them, schedule an appointment for 8am the next morning, show up at their house, have them sign an SOA right then, present a new plan and enroll them.

For Medicareful, you can call a client, have them do an SOA electronically, present the plan over the phone and have them enroll electronically ALL IN ONE PHONE CALL.

I think this is pretty big news. Maybe it's just not out there yet?!?

----------



It's probably not in the AHIP training because the 2018 MMG came out on July 20th which is after the AHIP training was developed. Typically, the MMG comes out around the first week in June, it was about a month and a half late this year.

I am going to blog on all the agent relevant changes later today. I think there are about 15-20 things agents need to know. Also, as the carriers digest the MMG, a consensus will develop around what everything means. We might interpret things one way and a carrier sees it differently, but generally, it crystallizes into a pretty uniform standard.

For example, I'm also trying to get clarification on some requirements around CMS approval of BRC's. The wording seems a bit contradictory. We may be able to use generic BRC's again for permission to contact and with the same day SOA, that might make direct mail cost effective again. Not 100% sure on that.
Thanks for the update Craig. I'm definitely excited about using the Medicareful SOA.
------------------------------------
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