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Medicare Part D Marketing Guidelines

By Clifford Ford,2014-01-20 21:34
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Medicare Part D Marketing Guidelines

Medicare Part D Marketing Guidelines

    Fact Sheet

What are Medicare-approved Prescription Drug Plans permitted

    to do?

    ? Call potential enrollees directly.

    ? ? ? Plans must honor national and state “do not call” lists, as well as individual

    requests to not be called again.

    ? ? ? Plans are allowed one or two follow-up calls if they do not reach potential

    enrollees the first time. If they still do not reach them after the third attempt,

    plans cannot follow up again for six months. ? Send direct mail to potential enrollees.

    ? ? ? As with phone calls, plans are allowed one or two follow-up letters if they

    do not reach potential enrollees the first time. If they still do not reach them

    after the third attempt, plans cannot follow up again for six months.

    ? Enroll people online.

    ? Visit potential enrollees at their homes.

    ? ? ? Plans are only allowed to visit a potential enrollee after they have obtained

    his/her expressed permission to do so. ? Offer beneficiaries or potential beneficiaries an abridged formulary.

    ? ? ? Plans can also answer formulary questions with answers specific to a

    beneficiary’s medication needs. If a beneficiary asks for a formulary, for

    convenience a plan representative can, for convenience, obtain information

    just for the drugs that the beneficiary in question takes.

    ? ? ? If, however, the beneficiary asks for a comprehensive formulary, the plan is

    required to send it to him/her.

    ? Conduct sales presentations in a provider’s place of business (pharmacy,

    doctor’s office, long-term care facility).

    ? ? ? The presentation must take place in a common area, however. If the

    presentation is in an area that is at all restricted, it may be an improper

    action. (See: Center for Medicare and Medicaid Services (CMS)

    MARKETING MATERIALS GUIDELINES, p. 127)

What are Medicare-approved Prescription Drug Plans NOT

    permitted to do?

    ? ? ? Enroll beneficiaries over the phone during a solicitation call.

    ? ? ? Plans can, however, enroll beneficiaries if they have called the plan with

    the explicit purpose of enrolling.

    ? ? ? Initiate a request for a house visit.

    ? ? ? A plan representative can respond to a request for a house visit, but s/he

    cannot ask to do so.

    ? ? ? If s/he does ask to visit a beneficiary at home before the beneficiary

    inquires about a home visit, or if s/he implies that any plan info can only

    be distributed during a home visit, s/he is acting improperly. (See CMS

    MARKETING MATERIALS GUIDELINES, p. 69)

    ? ? ? Solicit members or market any of their plans door-to-door.

    ? ? ? Refuse an explicit request for a comprehensive formulary.

    ? ? ? Process any enrollment applications before November 15, 2005.

    ? ? ? Plans can accept enrollment applications before November 15, however.

    What are providers permitted to do?

    ? ? ? Distribute and/or make available plan marketing materials.

    ? ? ? Providers can display posters for different plans.

    ? ? ? They can also make available PDP enrollment applications.

    ? ? ? They cannot, however, make available MA-PD (or MA) enrollment

    applications.

    ? ? ? Provide patients with information about different plans’ benefits

    ? ? ? Educate patients on what the kind(s) of plan(s) that would be best for them.

    ? ? ? Providers cannot advocate for, or steer any patients towards, any one plan

    or group of plans. They can only educate.

    ? ? ? Allow presentations by plan representatives in their places of business.

    ? ? ? The provider must ensure that the presentation is in a common area with

    open access to anyone who wants to attend.

    ? ? ? The provider must ensure that the presentation does not take place

    anywhere health care services are provided, such as behind a pharmacy

    counter.

    ? ? ? If access to the presentation is at all restricted in any way, the presentation

    may be improper. (See: CMS

     MARKETING MATERIALS GUIDELINES, p. 127)

    What are Providers NOT permitted to do?

    ? Accept any enrollment applications.

    ? Rank order or highlight any of the plans they discuss.

    ? Advocate for any particular plan or group of plans.

    ? ? ? Any phrases such as, “You should enroll in this plan,” or “I use this plan

    and I think it would be good for you too,” are strictly prohibited.

    ? ? ? Any hint or implication that a doctor is outwardly favoring any one plan

    over any other apart from offering plain factual evidence about plan

    benefits that correspond with patients’ drug needs – is strictly prohibited.

    How to report potentially improper conduct If you think, or have reason to believe, that a prescription drug plan and/or a provider

    may have been acting improperly, you may want to report their activities. Below are

    some key contact information for persons and organizations that deal with Medicare

    fraud, waste, and abuse.

    CMS

    Theresa Linkowich is the CMS point-person for reporting potentially improper conduct

    through November 15.

    She can be reached at (410) 786-9249, or at Theresa.Linkowich@cms.hhs.gov.

    After November 15, CMS will be handling any cases of potentially improper conduct

    through eight different private contractors called Medicare Rx Integrity Contractors

    (MEDICs). HAP will provide contact information for the MEDICs when it is available.

    Senior Medicare Patrols

    SMPs are organizations in every state whose purpose is to locate and report potential

    fraud or abuse.

    Find your local SMP at: http://www.aoa.gov/smp/grantee/grantee_state.asp

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