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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 FairsMarketingPre-enrollment materials are permitted
You can accept enrollment forms
Can collect lead information from attendees
Can hand out businessCards or marketing withcontact information
EducationalNo marketing
materials permitted
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 Yes No Yes Yes/optional YesScope of Appointment (SOA)*
No(Unless they require a 1 on 1 following the presentation)
Yes No(Unless they require a 1 on 1 following the presentation)
No 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 walk-in 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
Selling – Yes (Secure SOA)
“Future contact” Permission to Contact (Lead Card)
Yes, if prospect wants agent to contact them after a meeting
No Yes No Educational-No
Selling-Yes
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
Selling-Yes
Informational guides, promotional items and banners
Yes Yes Yes Yes Educational-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 CardsPlease 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.
Yes No Yes Yes (Upon request by the beneficiary)
Educational – Yes (Upon request by the beneficiary)
Selling – Yes
Ability to conduct plan-specific sales presentation
Formal - Yes(Full Presentation)
Informal – No
Yes (Full Presentation)
Yes No Educational – No
Selling – No
Marketing Materials approved by CMS
Yes Yes Yes Yes Educational – Yes
Selling – Yes Distribution of Benefits at a Glance
Yes Yes Yes No Educational-No
Selling-Yes
Distribution of Pre-Enrollment Kits(SBs and Apps)
Yes(Complete Kit)
Yes Yes No Educational – No
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
Advertisement needs to include scope of product language and disclaimers
Formal – Yes
Informal – No
Yes Yes No Educational – No
Selling - Yes
Advertisement needs to include educational event disclaimer
No No No Yes Educational – Yes
Selling - No
Advertisement needs to be approved by CMS
Yes Yes Yes Yes Educational-Yes
Selling Yes
Compliant (e.g., non-steering) provider participation – Guest Speaker
Yes No Yes Yes Educational-Yes
Selling-Yes
Accept enrollments
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 (Formal, Informal, *Educational)
• Explain enrollment/disenrollment periods (Formal, Informal, Educational)
• Explain premiums, co-insurance & co-pays (Formal)
• If using a PowerPoint or flipbook to guide you, be sure to cover all slides within your presentation
– 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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