Advertising...?

[TonyC]

Hi all,

The CMS website seems to infer that if you work with a company that offers leads where Seniors CALL you...you are ok. However, if you approach THEM...its a no-no....leading to fines, appointment nulifications, etc.

http://www.appliedga.com/compliance/2012_MarkGuidelines.pdf

QUESTION(s) for CMS
1. How do they know where you got the call from?
2. How do they know you didn't pass out your business card and get the lead (although this seems to be a grey area).
3. How do they know the Senior wasn't referred to you?
4. How do you CYA on this type of business?
5. Can you advertise Price? (Med. supps from $25 mth?)

thanks

~T

 

[Chazm]

You can approach people with med supps. Don't get MAPD rules confused with supps.

They obviously don't know if a client calls you or you called them but if you are marketing incorrectly with MAPD's you will probably eventually get caught.

 

[TonyC]

You can approach people with med supps. Don't get MAPD rules confused with supps.

They obviously don't know if a client calls you or you called them but if you are marketing incorrectly with MAPD's you will probably eventually get caught.

Hmmm....me thinks they (gov.regulators) pose as Med Adv. Buyers...and monitor ads, etc. "That's Most Likely" how they catch someone. However, I was referring to LEAD COMPANIES who market "both" Med.Supps and Adv. Leads. If you do a Google search for Medicare Advantage...you'll see the leads companies who advertise Med.Advantage Plans...and they even put price in their ads...which i believe is a "no-no."

So...the questions above have not been addressed....and that is basically what i numbered above.

thanks for your input.

 

[Chazm]

First I've ever heard that you can't put a price on MAPD ads. I see $0 premium plans advertised all the time.

And one of your questions asked if you can say, $25 med supps, and yes you can because its a MED SUPP. Not sure how none of your questions were answered when Medicare doesn't know if a client calls you. You have them fill out a SOA and sign it. That's how they know

You are not allowed to call for MAPD's. they have to call you, by an advert, a lead card or referral.

What kind of leads are you referring to? DM? Your own website generated lead? Internet lead?

 

[TonyC]

First I've ever heard that you can't put a price on MAPD ads. I see $0 premium plans advertised all the time.

And one of your questions asked if you can say, $25 med supps, and yes you can because its a MED SUPP. Not sure how none of your questions were answered when Medicare doesn't know if a client calls you. You have them fill out a SOA and sign it. That's how they know

You are not allowed to call for MAPD's. they have to call you, by an advert, a lead card or referral.

What kind of leads are you referring to? DM? Your own website generated lead? Internet lead?

Chaz,

I was referring to the language that CMS is using which suggest that if you advertise a Medicare Sup Plan...you cannot pitch a Medicare Advantage Plan. If this is the case, how can you justify working with a Lead company that does just that?

So apparently you can't purchase (or aren't supposed to) or work leads that were advertised as Med Sups..and turn them into a Med Advantage Lead.

Anyone else hear this?

What's the rule on this form of Lead?

thanks!

 

[SportsNut]

Hi all,

The CMS website seems to infer that if you work with a company that offers leads where Seniors CALL you...you are ok. However, if you approach THEM...its a no-no....leading to fines, appointment nulifications, etc.

The leads that you mention are predominently internet leads and the respondent has initiated the contact by leaving their name, address and phone number. No different than if they called your office and you weren't there, but they left you a message. When you return their call, this is not the same thing as you initiating the call. You are responding to their inquiry which changes the dynamic here.

If you are buying internet leads you are not the one doing advertising either. I'm not sure what onus falls on the lead company for compliance here, but I did read about the requirement being different and distinct areas on the website so people know what they are looking at by heading, etc. Not sure beyond that.

Also, unless you are going to see people f2f there is no requirement for a SOA. Aetna (or maybe Ritter, not sure) has suggested submitting a SOA anyway and indicating that it was a phone and/or fax appt, not f2f, just so CMS can see that it wasn't just omitted and not a f2f appt. Ok by me.

 

[TonyC]

The leads that you mention are predominently internet leads and the respondent has initiated the contact by leaving their name, address and phone number. No different than if they called your office and you weren't there, but they left you a message. When you return their call, this is not the same thing as you initiating the call. You are responding to their inquiry which changes the dynamic here.

If you are buying internet leads you are not the one doing advertising either. I'm not sure what onus falls on the lead company for compliance here, but I did read about the requirement being different and distinct areas on the website so people know what they are looking at by heading, etc. Not sure beyond that.

Also, unless you are going to see people f2f there is no requirement for a SOA. Aetna (or maybe Ritter, not sure) has suggested submitting a SOA anyway and indicating that it was a phone and/or fax appt, not f2f, just so CMS can see that it wasn't just omitted and not a f2f appt. Ok by me.

Sports...not what i'm saying.

Appreciate the input...but read the post right ABOVE YOURS.

 

[Chazm]

Chaz,

I was referring to the language that CMS is using which suggest that if you advertise a Medicare Sup Plan...you cannot pitch a Medicare Advantage Plan. If this is the case, how can you justify working with a Lead company that does just that?

So apparently you can't purchase (or aren't supposed to) or work leads that were advertised as Med Sups..and turn them into a Med Advantage Lead.

Anyone else hear this?

What's the rule on this form of Lead?

thanks!

It's not that way. If a med supp potential client calls you and they change the conversation to MAPD you can get a scope if you want to meet with them.
I think what cms is trying to get across is that you can't cold call for med supps and change the conversation to MAPD's. it's a loop hole that people were using.

You can't bring up MAPD's if they are calling about Med Supps.

 

[hassy99]

It's not that way. If a med supp potential client calls you and they change the conversation to MAPD you can get a scope if you want to meet with them.
I think what cms is trying to get across is that you can't cold call for med supps and change the conversation to MAPD's. it's a loop hole that people were using.

You can't bring up MAPD's if they are calling about Med Supps.

You are so right. A form has to be signed. 48 hours before face to face. The product to be discussed initialed in appropriate box. And signature. The only exceptions are for walk ins (which you have to report) and seminars. This rule for CMS regulated offerings (pdp and ma)

I know many agents cheat on this. But all it would take is one complaint (could come from another agent to start that process) or section A. And you could be in trouble
I mail out the scope to prospects with a stamped return envelope. And schedule the appt accordingly

Of course med supps do not have this requirement

Quite a bit. But it can be managed

 

[TonyC]

You are so right. A form has to be signed. 48 hours before face to face. The product to be discussed initialed in appropriate box. And signature. The only exceptions are for walk ins (which you have to report) and seminars. This rule for CMS regulated offerings (pdp and ma)

I know many agents cheat on this. But all it would take is one complaint (could come from another agent to start that process) or section A. And you could be in trouble
I mail out the scope to prospects with a stamped return envelope. And schedule the appt accordingly

Of course med supps do not have this requirement

Quite a bit. But it can be managed

Thanks Hassy,

Yep...that's what i thought. Good advice.
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It's not that way. If a med supp potential client calls you and they change the conversation to MAPD you can get a scope if you want to meet with them.
I think what cms is trying to get across is that you can't cold call for med supps and change the conversation to MAPD's. it's a loop hole that people were using.

You can't bring up MAPD's if they are calling about Med Supps.

Thanks Chaz,

Looks like they are trying to keep agent/telemarketers from pushing this product too hard. Afterall, it is a gov.sponsored program...and they don't want it anymore broken than it already is.