Compliance Reminders Heading Into AEP

Pre-Warming Activities

Prior to the Medicare Annual Election Period (AEP), you may have questions surrounding what you can and cannot do to market plans before October 1, 2017, which is the start of the AEP marketing period. 

The Centers for Medicare & Medicaid Services (CMS) does not permit any marketing of 2018 plans prior to October 1.  Below is a good reminder about what activities are considered “marketing” and must wait until October 1 or later.

“Marketing” includes-

  • Contacting prospects or current clients to solicit a personal/individual marketing appointment
  • Discussing any 2018 plan options, rates or benefits on phone calls or at an appointment
  • Holding, promoting or advertising sales/marketing events where 2018 plan options will be discussed
  • Obtaining a 2018 Scope of Appointment form
  • Completing an enrollment application

If the ultimate purpose is to contact clients to solicit a personal/individual appointment for AEP, or scheduling an appointment for AEP, that is considered marketing activity for 2018 plans.

However, if a client calls you about their Annual Notice of Change (ANOC) or Evidence of Coverage (EOC) mailing, you may respond to inbound questions and discuss only the changes for the plan a member is currently enrolled in. You cannot discuss 2018 plan options until Oct. 1, 2017. But you could schedule an appointment to take place Oct. 1 or later on the same inbound call. Agents may not market to members receiving Service Area Reduction (SAR) Notices until October 2.

But, if the beneficiary is entitled to another enrollment period, like a Special Election Period (SEP), or if they are in their initial eligibility period, continue to operate as normal.

If you have questions about this article or other compliance questions, please contact our compliance department, or ask your marketer.

 

Registering Sales and Educational Events

During this AEP season, please remember that in order to stay compliant with the CMS Medicare Marketing Guidelines, all sales/marketing events and all educational events must be registered properly with each carrier.  
The table below provides registration details and directions.  

Carrier

Reporting template and e-mail address

What type of events need reported

Submission Deadlines

UnitedHealthcare

Access the Event Reporting Form on www.uhcjarvis.com.  After entering event information on the form, double click the Validate and Submit button on the New Events tab.  (Or, agent can save the form and send it to the UHC local market for entry.)

Click here for the form

Sales and Educational

At least 14 calendar days prior to the event

Aetna-Coventry

Email completed “CMS Seminar Reporting Template” to medicaresemi@aetna.com

Agents must contact their Aetna Regional Market Contact for the form (form varies by market).

Sales and Educational

At least 10 calendar days prior to the event’s scheduled date

Cigna HealthSpring

Email completed to compliance@seniormarketsales.com and it will be submitted.

Click here for the form

Sales and Educational

No later than the 13th of the month prior to the event.

Humana

Agent must contact the local MarketPOINT Manager to obtain the form and request approval. 

Sales and Educational

At least 14 business days ahead of the event.

SilverScript

Email completed “Sales Event Template” to producersalesresource@caremark.com

Click here for the form

Sales and Educational

At least 2 weeks prior to event (At least 4 weeks prior to events in a CVS store)

Please let us know if you have additional questions.