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.

© 2022 MMIT
Lauren Flynn Kelly

Lauren Flynn Kelly Managing Editor, Radar on Medicare Advantage

Lauren has been covering health business issues, including drug benefits and specialty pharmacy, for more than a decade. She served as editor of Drug Benefit News (the predecessor to Radar on Drug Benefits) from 2004 to 2005 and again from 2011 to 2016, and now manages Radar on Medicare Advantage. Lauren graduated from Vassar College with a B.A. in English.

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