Ritter Insurance Marketing

UPDATE:  CMS 2009 Marketing Rules for Medicare Advantage and Prescription Drug Plans

Coventry Health Care previously provided in a 3-part series of communications detailed information on new CMS regulations and guidance, which went into effect on September 18, 2008 and impacts the 2009 selling season. You may review and download copies of all previous communications on the secure broker portal at www.AdvantraFreedom.com.

The latest CMS Marketing guidance released on October 8 and 17, 2008 clarifies requirements for implementing the new MIPPA regulations. We are pleased to provide you and your associates with this essential follow-up information, and CMS update highlights.  

Scope of Appointment

CMS has clarified earlier guidance regarding the requirements for documenting with a beneficiary in advance the scope of the appointment. 

• A state-licensed representative is required when there is marketing activity involved.
• Brokers/agents selling Coventry Medicare Advantage and/or Prescription Drug Plan products are required to secure and maintain documented agreement from the beneficiary prior to the appointment, whether that be a signed written form (document) or a verbal recording, as to the type of products that will be discussed with them at the appointment (e.g., MA, PFFS, MSA, PDP or CCP).
• Brokers/agents may not market any health care related product beyond the scope agreed upon by the beneficiary, and documented prior to the appointment. (Example:  If a beneficiary has agreed to an in-home appointment to discuss a PDP product, the agent may not discuss an HMO product during that meeting, even upon beneficiary request.  The agent may leave HMO plan information and have the beneficiary sign a scope of appointment / sales appointment confirmation form to discuss the HMO product at a separate appointment that must be scheduled at least 48 hours later.)
• A beneficiary may sign a sales appointment confirmation form at a marketing presentation for a follow-up appointment.

Click Here to view a Coventry-issued, CMS-approved Sales Appointment Confirmation Form.  This document is also available for download on the secure Broker Portal. 

Proper use of the Sales Appointment Confirmation Form

• The form must be completed and returned by the Medicare beneficiary or Medicare-eligible person in advance of the scheduled appointment when Coventry Medicare products will be discussed.
• Sales Appointment Confirmation Form is required for any face-to-face personal/individual appointment with a beneficiary. 
• Sales presentations do not require documentation of beneficiary agreement because the scope of products that will be discussed should be indicated on all event advertising materials.
• A beneficiary cannot agree to the scope of appointment over the phone and then sign the form at the beginning of the appointment.  If phone recording capability is not available, a form may be mailed to the beneficiary that can be returned and maintained as written documentation.

Click Here to access Coventry’s handy guide for Sales / Marketing in Health Care Settings or Educational Events

 Reminders:

• Educational Event is an event that is sponsored by the Medicare plan or by outside entities, and promoted to be educational in nature, not to steer toward specific plans, and have multiple vendors. No marketing or sales activity may occur at an educational event. (Examples: health information fairs, conference expositions, state-or community-sponsored events.)
• CMS requires this disclaimer when an educational event is organized, sponsored or promoted:  “This event is only for educational purposes and no plan specific benefits or details will be shared.”
• Sales Event is an event that is sponsored by the Medicare Advantage plan or another entity with the purpose of marketing to potential members and steering, or attempting to steer potential members toward a specific or limited number of plans.

Click Here to access Coventry Sales Event Reporting Template. Agents and/or Brokers are to submit notification of all Sales Event activity for all Coventry Medicare products to Coventry Broker Services on/before the 17th of every month.  Cancellations must also be reported.

Please direct questions and comments regarding Coventry Health Care 2009 products and AEP readiness, or the new CMS regulations and guidance to your marketing organization.  Or, you may contact Coventry Broker Services at: 1-866-714-9301, Monday-Friday, 8:00 a.m. – 8:00 p.m. ET.