By BluePeak Advisors
May 26, 2021
On
Friday May 28th, at 5pm ET, CMS will provide Plan Sponsors access to the new
HPMS marketing module. The new marketing material module has enhanced
functionality and will provide tools to Plans to facilitate tracking its
marketing materials. Materials submitted before May 28 will continue to
be available through a legacy material link. The new module will allow Plans
to manage the life cycle of materials.
In
addition, CMS has created a new process for Plans who utilize third-party
created and distributed multi-plan materials. Effective May 28 the author
of the third-party material will be responsible for coordinating with Plans
before material submission. There will no longer be a lead plan or
affiliated plan associated with multi-plan marketing material. Each Plan
may choose to opt-in or opt-out of the use of the CMS approved material.
In order to coordinate third-party, multi-plan materials, the Sponsor will have
to grant access to the third-party. Access is limited to submission of
multi-plan materials and the designee will not be able to view other materials
on behalf of a Sponsor. Make sure your organization grants access to the
entity who is creating multi-plan materials.
CMS
also reminded plans it will not be releasing an updated Medicare Communication
and Marketing Guidelines (MCMG) for calendar year 2022. Policy guidance
contained in the MCMG has been put into regulations at 42 CFR Part 422 Subpart
V and 423 Subpart V. Make sure you update your policies and procedures to
reflect this reference change.
Sponsors
and third parties will have to use the new HPMS Marketing Module for all
submissions after 5 pm EST on May 28, 2021. A new user guide will be available
in HPMS to assist staff with how to navigate the new functionality.
MMP
plans will receive updated state specific guidance before the end of August.
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