Comments: 2020 Final Medicare Communications and Marketing Guidelines
April 4, 2019
Comments
We continue to be disappointed that these guidelines do not offer sufficient guidance for how Medicare Advantage (MA) should market plans with new supplemental benefits. Guidance on these supplemental benefits is absolutely vital, as the risk of such benefits is that they will enable sponsors to cherry-pick beneficiaries and inappropriately steer potential enrollees. CMS continues to lose sight of valuable opportunities to protect people with Medicare.
The availability of supplemental benefits must not become merely or primarily a sales tool and sponsors must not be permitted to use supplemental benefits as a marketing device to persuade beneficiaries into their plans. We are especially concerned that agents and other sales personnel will ask individuals about their conditions and steer them toward specific plans in violation of anti-discrimination rules, and this guidance continues to do nothing to assuage our concerns. Cherry-picking and lemon-dropping must not be permitted through lax oversight.
We urge CMS to establish strict rules against such targeting and suggest that all shareable information about every plan be divulged to potential enrollees, empowering them to choose the appropriate plans for themselves. This may require plans to categorize benefits in a standard way to allow beneficiaries to understand the benefits catalog as a whole. Both CMS and plan sponsors must be vigilant for unusual spikes in enrollment or enrollment patterns that might reveal inappropriate steering of enrollees.
Any changes to the Medicare program must aim for healthier people, better care, and smarter spending—not paying more for less. As policymakers debate the future of health care, we will provide our insights here.
Thinking ahead to Medicare's future, it’s important to modernize benefits and pursue changes that improve how people with Medicare navigate their coverage on a daily basis. Here are our evolving 30 policy goals for Medicare’s future.
You can help protect and strengthen Medicare by taking action on the important issues we are following, subscribe to newsletter alerts, or follow along on social media. Any way you choose to get involved is a contribution that we appreciate greatly.
Comments: 2020 Final Medicare Communications and Marketing Guidelines
We continue to be disappointed that these guidelines do not offer sufficient guidance for how Medicare Advantage (MA) should market plans with new supplemental benefits. Guidance on these supplemental benefits is absolutely vital, as the risk of such benefits is that they will enable sponsors to cherry-pick beneficiaries and inappropriately steer potential enrollees. CMS continues to lose sight of valuable opportunities to protect people with Medicare.
The availability of supplemental benefits must not become merely or primarily a sales tool and sponsors must not be permitted to use supplemental benefits as a marketing device to persuade beneficiaries into their plans. We are especially concerned that agents and other sales personnel will ask individuals about their conditions and steer them toward specific plans in violation of anti-discrimination rules, and this guidance continues to do nothing to assuage our concerns. Cherry-picking and lemon-dropping must not be permitted through lax oversight.
We urge CMS to establish strict rules against such targeting and suggest that all shareable information about every plan be divulged to potential enrollees, empowering them to choose the appropriate plans for themselves. This may require plans to categorize benefits in a standard way to allow beneficiaries to understand the benefits catalog as a whole. Both CMS and plan sponsors must be vigilant for unusual spikes in enrollment or enrollment patterns that might reveal inappropriate steering of enrollees.
Reference
Recent Documents
Testimony: Legislative Proposals to Support Patient Access to Telehealth Services
Comments on the 2025 Advance Notice
Comments Supporting the Complete Rescission of the 2018 Association Health Plan Final Rule
Comments on Proposed Changes to Medicare Advantage and Part D for 2025
Statement for the Record on Medicare Advantage Marketing and the Enrollee Experience
Medicare Prescription Payment Plan (MPPP) Draft Guidance
Any changes to the Medicare program must aim for healthier people, better care, and smarter spending—not paying more for less. As policymakers debate the future of health care, we will provide our insights here.
Thinking ahead to Medicare's future, it’s important to modernize benefits and pursue changes that improve how people with Medicare navigate their coverage on a daily basis. Here are our evolving 30 policy goals for Medicare’s future.
You can help protect and strengthen Medicare by taking action on the important issues we are following, subscribe to newsletter alerts, or follow along on social media. Any way you choose to get involved is a contribution that we appreciate greatly.