Recent regulatory changes as well as program modifications being
considered by CMS will likely allow greater flexibility in Medicare Advantage
plans' efforts to engage MA and Part D plan members throughout the year. One of
these is the reinstatement of the MA open enrollment period (OEP), which allows
members to switch plans during the first 90 days of the year.
While the return of the OEP technically gives plans more time to attract potential enrollees, it also adds to marketing budgets and means customer retention is more important than ever, said Matt Feret, chief sales officer and executive director, Medicare, with Aetna Inc., who spoke at the Second National Medicare Advantage Summit.
Plans will have to be careful not to engage in "targeted marketing" efforts that would, for example, go after competitors' enrollees and inform them of the opportunity to switch, said health care attorney Kelli Back at the conference. More general, educational material will be acceptable, added Back and Feret.
Another meaningful marketing-related change in CMS's recent rule is the addition of "communications" to the newly renamed Medicare Communications and Marketing Guidelines that are revised annually. By categorizing certain items as communications, this created a much narrower definition of marketing materials that are subject to agency review, said Back.
Also speaking at the conference, Michael Adelberg, a principal with FaegreBD Consulting and a former top CMS MA official, pointed out that CMS in the past five years has imposed 16 fines for activities that fall under a broad definition of marketing and communications. With more and more plans coming onto the market and CMS providing greater marketing flexibilities, it will be important that plans continue to make sure their practice are in sync with current guidelines.
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