Important AEP Marketing Reminders

As we prepare for AEP, we want to remind all of our valued agents of a few critical things related to marketing.

1. All marketing to be leveraged by your organization or downlines must be reviewed, and approved by the carrier and filed in HPMS prior to use.  This includes:

• Marketing created by your organization,
• Marketing purchased from others, and
• Marketing utilized by lead generators/aggregators to create the leads your organization purchases.

2. Leads from sources like (but not limited to) those listed below are not compliant and not permitted.  For leads to be compliant it must be abundantly clear that the beneficiary is giving consent to be contacted about Medicare products.  If you are using any of these types of sites, you must cease use immediately.  Sites in question include experiences/flows that lead the beneficiary to believe that they are going to be:

• Completing an astrology questionnaire.
• Requesting information related to food stamps and/or free samples without clearly and explicitly indicating when the inquiry shifts to a Medicare Advantage permission to contact. (Anything in this category your agency is intending to use must be reviewed and approved by Humana)
• Entering a chance to win money/enter a raffle.

3. Sales agents must ensure they are using valid election periods. Please remember that sales agents are prohibited from using the Special Election Period (SEP) ”Other Exceptional Circumstances.” To use this SEP, a beneficiary must call 1-800-Medicare to make a request regarding eligibility and permission for use based on Other Exceptional Circumstances, which may include marketing misrepresentations.  CMS will review these requests on a case-by-case basis along with the supporting details and documentation to determine whether the beneficiary’s circumstance is eligible for this SEP. Use of this SEP by sales agents is not permitted and inappropriate use may be subject to corrective action.  For more information regarding this SEP and its approval process, please refer to Ch.2 of the Medicare Managed Care Manual, sub-section 21 “SEP for Other Exceptional Circumstances” and 42 CFR 422.62(b)(27).

Thank you for your help in ensuring a strong and compliant AEP.  If you have any questions, please call us at 866-568-9649!