Ritter Insurance Marketing, Craig Ritter

CMS Guidance on Events Marketing, Educational Events and Health Fairs

I pieced some information for agents as a refresher on CMS regs on different types of Events.  CMS treats events differently based on the purpose of the event.  You should know what type of event you are having as this dictates when you can do and what you cannot do.  Following are my notes:

Types of Events

CMS Managed Care Manual, Chapter 3 (Rev. 05/07/2010)

Only CMS approved materials can be used.

Educational Events (Section 70.7):

Defined by the way in which an event is described to the beneficiary.  An event hosted by the plan sponsor or an outside entity is considered an educational event if the event is advertised to beneficiaries as “educational.’’

  • CAN – Provide materials that meet the CMS definition of educational, display a banner with plan name and/or logo, provide promotional items with toll-free number/website, provide business card if the beneficiary requests information on how to contact the agent to request additional information.
  • CANNOT – Discuss plan-specific benefits, distribute plan-specific materials, distribute or display business cards, collect applications, schedule appointments, ask if participants would like plan information.
  • ENSURE – all guidelines for educational events are followed when event is marketed as educational.
  • DO NOT – file with CMS as a Sales Presentation/Sales Event.  For such events, adhere to the guidelines for Marketing/Sales Events (70.9).

Health Fair and Health Promotional Events (Section 70.8):

Defined by the venue, the room design and the way in which the event is advertised to the Medicare beneficiary. Typically casual in atmosphere and are generally comprised of various participant booths manned by staff to answer questions and hand out material. May only reactively answer questions posed by interested parties. If advertised as an educational event, then the plan must abide by the rules for an educational event.

  • CAN – Promote the event, serve refreshments only, hand out pre-enrollment marketing material (including enrollment forms), answer attendee questions.
  • CANNOT – Provide a Sales Presentation, collect applications, provide meals.
  • ENSURE – all guidelines are followed, including the provider setting for a Health Fair event.
  • DO NOT – file with CMS as a Sales Presentation/Sales Event.  For such events, adhere to the guidelines for Marketing/Sales Events (70.9).
  • If offered, individual door prizes/raffles (including a combination of door prizes/raffles) cannot exceed the $15 limit each, based on the retail purchase price of the item (please refer to §70.2 for further guidance). Disclaimers should be present to advise that there is no obligation to enter and/or be eligible for the door prizes/raffle.

Marketing/Sales Events (Section 70.9):

Defined by both the range of information provided and the way in which the content is presented to the Medicare beneficiary. In addition, marketing/sales events are defined by the plan’s ability to collect applications and enroll Medicare beneficiaries during the event.

Two types:

1)     Formal Marketing/Sales Events: formal, structured in audience/presenter style where agent formally provides specific plan information via a presentation on the products being offered.  Must announce all products that will be covered during any formal presentation at the beginning of that presentation.

2) Informal Marketing/Sales Events: less structured, table/kiosk manned by agent who can discuss the plan’s products when approached by a beneficiary/representative of beneficiary.   Agent can proactively discuss the merits of a plan or plans to an interested beneficiary. If a beneficiary wants to enroll at an informal marketing event, a full presentation does not need to be completed before the application is accepted.

  • CAN – Promote the event, serve refreshments only, hand out pre-sale marketing material, formally present via a scripted talk, schedule one-on-one meetings with Scope of Appointment, provide nominal gifts, accept and perform enrollments.
  • CANNOT – conduct health screenings, compare one plan sponsor to another by name unless both plan sponsors have concurred, provide meals.

ENSURE – all guidelines are followed, submit calendar of Marketing/Sales events each month, noting type (formal or informal), follow established process for all cancelled events.

Posted by filed under All, CMS .

© Ritter Insurance Marketing