Compliance Training

Report
Event Compliance
Training
Types of Events - Educational
• Informational presentation
on Medicare topics
• Neither sales nor marketing
are permitted to take place.
Types of Events - Informal
• Marketing/Sales events, also referred
to as “lead generation” activities
•
Events are typically conducted in a
less formal environment that allow a
beneficiary to walk up to an agent &
learn more about product offerings
with a less structured presentation
• These events sometimes utilize a
table, kiosk or a recreational vehicle
(RV) that is manned by a plan sponsor
representative who can discuss the
merits of a plan’s products
Types of Events - Formal
• Marketing/Sales events are
usually structured in an
audience/presenter style
• Sales person or plan formally
providing specific plan sponsor
information via a presentation on
the products being offered
• The presenter usually presents
to an audience that may have
been invited to attend
Marketing/Sales Events
• Sales seminar or presentation that
a broker hosts aimed at promoting
specific benefits and/or services
• CAN accept & perform enrollments
at event
• These events must be submitted
to compliance prior to advertising
• These events must be submitted
to AGA for submission to a carrier
at least 7 days prior to the event
(preferably by the 10th of the
month prior)
Educational Events
• Events designed to inform
beneficiaries about Medicare
information and programs
• May not include any
sales/marketing activities
(e.g. giveaways, business cards, prize wheel)
• Must be advertised as “Educational”
• You have the option to submit these
events to CMS
Provider Marketing Events
• Marketing activities are permitted in
common areas of health care
settings
• Marketing activities are
prohibited in any areas where
patients receive health services
(e.g. exam/waiting room)
• Appointments with beneficiaries
residing in long term care facilities
must only take place upon request of
beneficiary
Health Fairs
Marketing
Educational
Pre-enrollment
materials are
permitted
No marketing
materials permitted
You can accept
enrollment forms
Can collect lead
information from
attendees
Can hand out business
Cards or marketing with
contact information
Cannot accept
enrollment forms
Cannot accept lead
information
Cannot hand out
business card or any
marketing materials
with contact
information
Definitions/
Permissible Activities
Marketing/Sales
Event
Personal/
Individual Sales
Appointment
Marketing in the
Health Care
Setting
Educational
Event
Health Fair
Principle Purpose
Selling
Formal/Informal
Selling
Selling
Education
Educational/Selling
Reportable to CMS
Scope of Appointment
(SOA)*
Yes
No
(Unless they require
a 1 on 1 following
the presentation)
No
Yes
Yes
No
(Unless they require
a 1 on 1 following
the presentation)
Yes/optional
No
Yes
No
(Unless they require a
1 on 1 following the
presentation)
Ability to set up a future
appointment
Yes
(Scope required prior
to appt, unless walkin to sales office)
Yes
(Scope required prior
to appt, unless walk-in
to sales office)
Yes
(Scope
required prior to
appt, unless walk-in
to sales office)
No
Educational – No
“Future contact”
Permission to Contact
(Lead Card)
Yes, if prospect
wants agent to
contact them after a
meeting
No
Yes
No
Attendance Sheet
Formal-Yes (Can’t be
a requirement)
Informal-No
No
Yes
No
No
Light Snacks and
refreshments only
Yes
Yes
Yes
Yes
(Meals are
permitted)
Educational-Yes
Yes
Educational-Yes
Informational guides,
promotional items and
banners
Yes
Selling – Yes
(Secure SOA)
Educational-No
Selling-Yes
Yes
Yes
Selling-Yes
Selling-Yes
Definitions/
Permissible Activities
Marketing/Sales
Event
Personal/
Individual Sales
Appointment
Marketing in the
Health Care
Setting
Educational
Event
Health Fair
Principle Purpose
Selling
Formal/Informal
Selling
Selling
Education
Educational/Selling
Distribution of Business
Cards
Yes
Yes
Yes
Yes (Upon request
by the beneficiary)
Educational – Yes
(Upon request by the
beneficiary)
Please Note: CMS clarified business
cards may NOT be stapled to any
marketing material. Stickers with
agent contact information may NOT be
applied to any approved materials,
doing so is altering what was
approved by CMS
Selling – Yes
Ability to conduct planspecific sales
presentation
Formal - Yes
(Full Presentation)
Marketing Materials
approved by CMS
Yes
Yes
(Full Presentation)
Yes
No
Educational – No
Selling – No
Informal – No
Yes
Yes
Yes
Educational – Yes
Selling – Yes
Distribution of Benefits
at a Glance
Yes
Yes
Yes
No
Educational-No
Selling-Yes
Distribution of PreEnrollment Kits
(SBs and Apps)
Yes
(Complete Kit)
Yes
Yes
No
Educational – No
Selling – Yes
Definitions/
Permissible Activities
Principle Purpose
Advertisement needs to
include scope of product
language and disclaimers
Advertisement needs to
include educational
event disclaimer
Advertisement needs to
be approved by CMS
Compliant (e.g., nonsteering) provider
participation – Guest
Speaker
Accept enrollments
Marketing/Sales
Event
Selling
Formal/Informal
Formal – Yes
Informal – No
No
Yes
Yes
Personal/
Individual Sales
Appointment
Marketing in the
Health Care
Setting
Educational
Event
Health Fair
Selling
Selling
Education
Educational/Selling
Yes
Yes
No
Educational – No
Yes
Selling - Yes
Educational – Yes
Yes
Selling - No
Educational-Yes
Yes
Selling Yes
Educational-Yes
No
Yes
No
No
Yes
Yes
Selling-Yes
Yes
Yes
Yes
No
Educational-No
Selling-Yes
*All producers are required to submit the completed Scope of Appointment for with each enrollment application (see page
XX for an example).
Compliant Presentation Tips
•
Always identify the types of plans you will
be covering
(Formal)
•
Explain eligibility requirements
•
Explain enrollment/disenrollment periods
•
Explain premiums, co-insurance & co-pays
•
If using a PowerPoint or flipbook to guide
you, be sure to cover all slides within your
presentation
(Formal, Informal, *Educational)
(Formal, Informal, Educational)
(Formal)
–
–
Benefits Information (Formal)
Medicare tips/Information (Informal)
Compliant Presentation Tips
• Show up early and be where you said
you’d be
• Do not make absolute statements
(e.g. “X plan is the best!” or “extraordinary”)
• Do not use high pressure tactics
• Do not make inaccurate statements
• See guidebook for a more detailed
listing of what to cover
Basic Medicare Comprehension
•
Part A [Hospital] coverage requires a
monthly premium
•
Part B [Medical] coverage does not
cover expenses outside the US
•
Part C [Medicare] plans must cover Part
A & B expenses
•
Special Needs Plans (SNP) are only for
beneficiaries with special healthcare
needs and those with Medicare &
Medical
•
There is financial assistance for Part B
& D [Prescription Drug] premiums for
low income households
Basic Medicare Comprehension
• The earliest one may be eligible to
submit an enrollment for Medicare
Advantage is 64 years, 9 months old
UNLESS they have ESRD or certain
chronic illnesses
• Annual Enrollment Period is
October 15 - December 7
• Understand how the Disenrollment
Period works
(January 1 – February)
Basic Medicare Comprehension
• A senior may choose to solely be
covered by Medicare and does not
need to enroll on another type of plan
• Make sure to check that the
beneficiary’s doctors/specialists
accept the plan FIRST
• Not all Medicare Advantage plans
cover prescription drugs
• Compare drug plan costs and find the
plan with the least out of pocket
expense
Basic Medicare Comprehension
• Understand the “donut hole” and how it
works
• Only RX amounts paid when in the hole
apply towards TROOP (true out of pocket
costs)
• Catastrophic Coverage begins when the
beneficiaries TROOP = $4,550
• When in the hole, beneficiary will only be
responsible for 50% of the brand name
drugs’ manufacturer cost plus a $2
dispensing fee
Personal/Individual Appointments
• Typically take place in a
beneficiaries home
• Face to face appointments
are considered
marketing/sales events by
CMS
• Scope of Appointment is
required for all personal
appointments
Questions

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