Jun 27, 2018
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 practices are in sync with current guidelines.
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