Are Your Client Reward and Incentive Programs Compliant?


Reward and incentive (RI) programs can only be offered to current enrollees. However, that doesn’t mean these programs cannot be introduced to potential enrollees. Learn how to market these programs and comply with the Medicare Marketing Guidelines (Section 110.2).

You Can Market to Potential Enrollees, But …

There are a few rules you will have to follow if you want to use RI programs on your marketing materials. In accordance with the MMG, brokers must ensure that all materials with rewards and incentive program information:

  • Are provided as an informative addition to marketing materials—not as a plan’s main appeal for potential enrollees.
  • Are provided to all potential enrollees without discrimination.
  • Are provided alongside plan benefit information.
  • Include information about every reward and incentive program offered by the plan being marketed.
    • Information cannot be limited to a single program, reward, or incentive.

A Few Important Notes About RI Programs

The Medicare Managed Care Manual (Chapter 4) has a few useful pieces of information that we think are useful for brokers to know or be reminded of.

  1. RI programs only apply to Medicare Advantage plans. They may not be offered with Part D plans, and it may be beneficial to clearly explain this to any interested client.
  2. “Nominal gifts as part of promotional activities are separate and distinct from RI Programs.” Again, it may be beneficial to explain this to any fellow broker or client.

Let Excelsior Show You More

You can find more broker-focused explanations of Medicare Marketing Guidelines on our online resource center. You can also find out how we are helping our brokers double, and sometimes triple, their business by contacting us.


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References
https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/mc86c04.pdf | https://www.cms.gov/Medicare/Health-Plans/ManagedCareMarketing/Downloads/CY-2018-Medicare-Marketing-Guidelines_Final072017.pdf

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