2022 Outlook: Increased Marketing Oversight Is Top MAO Compliance Concern

While CMS guidance and oversight regarding Medicare Advantage sales and marketing was rather uneventful under the Trump administration, several recent actions by the Biden administration signal a growing focus on Medicare marketing, including MA organizations’ use of third-party entities. The most notable of those was an October 2021 memorandum that explicitly reminded MAOs that they are responsible for the activities of first tier, downstream or related entities (FDRs), including third-party marketers with which they may not directly contract. CMS in that memo clarified that MA plans must submit all marketing materials to CMS prior to use, even when certain advertisements do not mention a plan by name, and reiterated this in its latest update to the Medicare Communications and Marketing Guidelines.

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