Reminder Regarding Third Party Marketing and Enrollment Websitess

April 6, 2015

Several weeks ago, Medicare Advantage carriers distributed a broker blast concerning CMS’s memo on Third Party marketing and enrollment websites, reminding Plans that they will be held responsible for broker/FMO Medicare Advantage website content.

“If a Plan/Part D Sponsor’s subcontractor, such as an agent/broker, is using a 3rd party websie to market or obtain beneficiary information for the purposes of marketing and/or enrollment into a Medicare Advantage or Prescription Drug Plan, the Plan/Part D Sponsor will be held responsible for the content of the website, as well as any agent/broker activity associated with the use of the inappropriate or misleading information, and will be subject to compliance actions”

Any broker or brokerage with a consumer facing, lead generation website and markets a specific plan (by either a logo or plan name) or has the intention of enrrollment, please submit the link to the named carrier for review. Not all websites need be uploaded to CMS; in fact, most do not, but websites must be reviewed by the plan. Not everyone has complied with this request.

If you have already to all applicable carriers about your website, you are not required to take further action. If you have not and have a website, please immediately send to each carrier. As a reminder, ANY MAPD materials, including websites, forms, advertisements, mailers that mention a specific plan must be submitted to the plan for review prior to use. Failure to do so could result in contract or appointment termination.

To view the CMS’ memo, click here.

As always, we thank you for your support and cooperation. For questions or comments, please email us at Compliance@NSGACommunications.com or you may call the toll-free number listed below.

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