On August 8, 2022, CMS issued an HPMS memo entitled, “Transfer of Submitted Multi-Plan Marketing Materials.” The memo announced CMS updates to the HPMS Marketing Module to allow third-party marketing organizations (TPMO) to transfer previously submitted multi-plan marketing materials to another consultant user when the original submitter is no longer performing the function for the TPMO (e.g., individual has left the TPMO or moved to a different position within the TPMO).
As stated in the current Medicare Communications and Marketing Guidelines (MCMG), CMS permits third parties to submit marketing materials directly to CMS on behalf of contracted plans when the marketing materials created by a third party include marketing content of and used by multiple plans. Note: If the third-party’s marketing materials mention only one sponsor organization, the plan should submit materials directly to CMS using the standard submission process.
ATTAC Consulting Group reminds plan sponsors that CMS holds them responsible for TPMOs acting on their behalf, including adherence to all provisions of the MCMG. This includes use of standard disclaimers on applicable marketing materials and the prohibition against providing misleading, confusing, or materially inaccurate information to current or potential enrollees.
Contact ATTAC to learn how our marketing and sales experts can assist your organization in interpreting and implementing the 2022 Medicare Communications and Marketing Guidelines.