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