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Reply to Bye Bye 48 Hour Scope     
Old 08-10-2017, 06:52 PM   #11
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Bye Bye 48 Hour Scope Re: Bye Bye 48 Hour Scope
Originally Posted by Devin01 View Post
Went to a NAHU Medicare meeting this week and CMS was there. They are not yet recognizing this and still giving guidance to follow 48 hrs when applicable.
Didn't CMS make the rule though? Maybe the people that were there just didn't realize it yet.
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Old 08-10-2017, 06:56 PM   #12
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Bye Bye 48 Hour Scope Re: Bye Bye 48 Hour Scope
Has anyone ever questioned the "next day appointment" explanation?
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Old 08-11-2017, 12:11 AM   #13
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Bye Bye 48 Hour Scope Re: Bye Bye 48 Hour Scope
This is great news but when does the elimination of the 48 rule take effect? I'm guessing January of 2018.
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Old 08-11-2017, 06:59 AM   #14
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Bye Bye 48 Hour Scope Re: Bye Bye 48 Hour Scope
We are running this through our compliance channels to see how they interpret it. When we hear back a definite answer, I will post it.

However, they (our compliance channels...ie carrier compliance departments) have stated as of now there are no changes to the 48-hour rule.

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Old 08-11-2017, 07:54 AM   #15
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Bye Bye 48 Hour Scope Re: Bye Bye 48 Hour Scope
Got this from UHC

Thank you for your question. We are aware of the recent update to the Scope of Appointment guidance in the latest release of the Medicare Marketing Guidelines (MMG) from the Centers for Medicare and Medicaid Services (CMS). We are currently reviewing our policy and business decisions regarding the updates. From a UnitedHealthcare policy perspective, at this time there is no change to the 48 hour cooling off period for obtaining a Scope of Appointment (SOA). Any changes based on the updated guidance from CMS or business decisions would be communicated appropriately to the field.
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Old 08-11-2017, 08:58 AM   #16
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Bye Bye 48 Hour Scope Re: Bye Bye 48 Hour Scope
Originally Posted by Bob Mayo View Post
This is great news but when does the elimination of the 48 rule take effect? I'm guessing January of 2018.
Bob, technically the guidance is effective as soon as it's practical to implement. So, I think the carriers are huddling with their lawyers and compliance folks before they implement the change and probably reaching out to their regional CMS offices to verify interpretation.

That said, as the MMG is currently worded, I really can't see any imaginable reason why a carrier would enforce the 48 hour cooling off period.

The MMG says SOA must be signed prior to the appointment, there is absolutely nothing in there that references 48 hours. It's like when your mom told you to wash your hands before supper, in my opinion. You don't need to wash your hands 48 hours before supper. (maybe a bad analogy!)

My guess is that everyone is just being very cautious, but unless CMS changes the MMG to reinstate the 48 hour rule, I really can't see another way to interpret this.

Clearly, agents need to follow the carriers' direction, so I would keep doing what you've always done until you hear differently from the carriers. That said, it would be a massive competitive disadvantage for a carrier to impose the 48 hour rule if others are not requiring it, per the new guidelines, so I think this is going to become clear in the next couple weeks (my opinion).

I am pushing carriers HARD on this, of course!

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Old 08-11-2017, 09:39 AM   #17
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Bye Bye 48 Hour Scope Re: Bye Bye 48 Hour Scope
Originally Posted by craig_ritter View Post
Bob, technically the guidance is effective as soon as it's practical to implement. So, I think the carriers are huddling with their lawyers and compliance folks before they implement the change and probably reaching out to their regional CMS offices to verify interpretation.

That said, as the MMG is currently worded, I really can't see any imaginable reason why a carrier would enforce the 48 hour cooling off period.

The MMG says SOA must be signed prior to the appointment, there is absolutely nothing in there that references 48 hours. It's like when your mom told you to wash your hands before supper, in my opinion. You don't need to wash your hands 48 hours before supper. (maybe a bad analogy!)

My guess is that everyone is just being very cautious, but unless CMS changes the MMG to reinstate the 48 hour rule, I really can't see another way to interpret this.

Clearly, agents need to follow the carriers' direction, so I would keep doing what you've always done until you hear differently from the carriers. That said, it would be a massive competitive disadvantage for a carrier to impose the 48 hour rule if others are not requiring it, per the new guidelines, so I think this is going to become clear in the next couple weeks (my opinion).

I am pushing carriers HARD on this, of course!
Mine said be home before dark. When I showed up after she thought I should have been home I would pull the whole "I still have a shadow outside so it's not completely dark". Yeah, that never went over so well.

I'm with you Craig on the carriers trying to figure out what they will do. And ultimately we have to follow whatever each carriers specific rules are. It's been my experience that they always err on the side of caution. Which means unless they get specific guidance from CMS (like an official memo that says, the 48 hour rule is no longer required) some carriers will still require it.

For me, I plan on following that until each carrier says we don't have to. It's just easier to do it than to have to fight with the carrier after the fact. And I'm definitely going to take advantage of the electronic SOA on my personal Medicareful site. As a matter of fact, within the next month or so I will be sending an email out to all of my MA/PDP clients with a link and instructions to go ahead and complete the SOA. That way I'm in compliance with any carrier who has the 48 hour rule still in effect. Additionally, it's one less form that has to be mailed/emailed, signed and returned.
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Old 08-11-2017, 09:46 AM   #18
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Bye Bye 48 Hour Scope Re: Bye Bye 48 Hour Scope
"...Bob Mayo on the keyboard, Bob Mayo . . .
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Old 08-12-2017, 11:26 PM   #19
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Bye Bye 48 Hour Scope Re: Bye Bye 48 Hour Scope
Originally Posted by wln417 View Post
"...Bob Mayo on the keyboard, Bob Mayo . . .

Wow, I've never had anyone pick up on this reference!

As you were...
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Old 08-13-2017, 09:23 AM   #20
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Bye Bye 48 Hour Scope Re: Bye Bye 48 Hour Scope
Originally Posted by craig_ritter View Post
Bob, technically the guidance is effective as soon as it's practical to implement. So, I think the carriers are huddling with their lawyers and compliance folks before they implement the change and probably reaching out to their regional CMS offices to verify interpretation.

That said, as the MMG is currently worded, I really can't see any imaginable reason why a carrier would enforce the 48 hour cooling off period.

The MMG says SOA must be signed prior to the appointment, there is absolutely nothing in there that references 48 hours. It's like when your mom told you to wash your hands before supper, in my opinion. You don't need to wash your hands 48 hours before supper. (maybe a bad analogy!)

My guess is that everyone is just being very cautious, but unless CMS changes the MMG to reinstate the 48 hour rule, I really can't see another way to interpret this.

Clearly, agents need to follow the carriers' direction, so I would keep doing what you've always done until you hear differently from the carriers. That said, it would be a massive competitive disadvantage for a carrier to impose the 48 hour rule if others are not requiring it, per the new guidelines, so I think this is going to become clear in the next couple weeks (my opinion).

I am pushing carriers HARD on this, of course!

If each company's lawyers are getting involved in the interpretation, then we're going to be in for a mixed mess! As an IMO, I'm sure you've discovered that every company's lawyers are "right", even when they come up with different conclusions. And they probably will come up with different rules.

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