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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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.
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!
"...Bob Mayo on the keyboard, Bob Mayo . . .
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!