2018 CMS Marketing Guidelines – 100.7 Third-Party Websites

July 21, 2017

A third-party website is defined as a site that is not owned by a Plan/Part D Sponsor, but by a company with whom the Plan/Part D Sponsor has a contract for the purpose of selling or promoting its products.

Website owners should contact the Plans/Part D Sponsors with which they contract to discuss the website submission process. When a website owner is contracted with multiple Plans/Part D sponsors, we suggest they coordinate the Multi-plan submission process for the website. See section 90.2.3, Plans/Part D sponsors are not required to submit third-party marketing websites to HPMS that do not include any plan-specific information.

Plans/Part D Sponsors must ensure that third-party websites with which the Plan/Part D sponsor contracts does not:

• Provide misleading information, such as identifying a Medicare Supplement plan as a Medicare Advantage Plan; or
• Use prohibited terminology, including unsubstantiated absolute superlatives.

Third-party websites may request, but not require, health status information.

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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