The 2018 Medicare Marketing Guidelines turned heads by removing the 48-hour Scope of Appointment requirement. Many agents are asking what this means in terms of compliance.
Let’s review what changed and what you’re still responsible for regarding Scopes of Appointment (SOAs).
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In the 2018 Medicare Marketing Guidelines (MMG), the Centers for Medicare & Medicaid Services say the following about SOAs:
“When conducting marketing activities, in-person or telephonically, a Plan/Part D Sponsor may not market any health care related product during a marketing appointment beyond the scope that the beneficiary agreed to before the meeting. The Plan/Part D Sponsor must document the scope of the appointment prior to the appointment.”
What’s noticeably absent from previous guidelines is language regarding how far prior to the appointment an SOA needs to be obtained. While the current guidelines, now known as the Medicare Communications and Marketing Guidelines (MCMG), still state that SOAs must be documented “prior to the appointment,” we interpret that to mean “same-day scopes” are compliant for any reason.
We interpret the MCMG to mean same-day scopes are compliant in all cases.
Note: Some carriers may understand the SOA rule differently or have their own policies, so it’s imperative that you operate within the guidelines of the carriers you represent.
What Does It Mean for You?
The new guidelines have the potential to streamline your entire sales process from lead to appointment, to presentation, to enrollment.
In the past, you had to delay meeting with a client interested in hearing about their health plan options until at least 48 hours after he or she signed the SOA. Now, that same client can request an appointment with you through a Scope, meet with you, and enroll in a health plan on the same day.
Additionally, if the client you’re meeting with indicates they’d like to talk about a health product they did not agree to discuss in advance, you can simply collect a second SOA for the additional product type and continue the appointment. It goes without saying, but that’s an easier way to do business.
If a client expresses interest in non-health products such as life, annuities, or final expense options with you, reserve that discussion for another appointment at a later time.
Did the Scope of Appointment Itself Change?
What’s required as part of an SOA remains the same, and you’re still responsible for following those rules. If you need a refresher, we’ve got you covered.
According to the MCMG, SOA documentation is subject to the following requirements:
- The documentation may be in writing, in the form of a signed agreement by the beneficiary
- Date of appointment
- Beneficiary contact information (e.g., name, address, telephone number)
- Written or verbal documentation of beneficiary or appointed/authorized representative agreement
- The product type(s) (e.g., MA, PDP, MMP) the beneficiary has agreed to discuss during the scheduled appointment
- Agent information (e.g., name and contact information)
- A statement clarifying that:
- Beneficiaries are not obligated to enroll in a plan
- Current or future Medicare enrollment status will not be impacted
- The beneficiary is not automatically enrolled in the plan(s) discussed
Additionally, an SOA isn’t required for an application taken at a compliant marketing/sales event. However, a beneficiary should sign an SOA at a compliant marketing/sales event in order to schedule a future appointment.
One Reason We’re Excited About These Changes
Ritter introduced a revolutionary electronic Scope of Appointment (eSOA) on their Medicareful platform last year, and now it’s more powerful for agents than ever.
Now, a lead visiting your personal Medicareful site can select the “Contact Us” button and open the compliant eSOA. By providing a few simple contact details and the product types they’re interested in, they create an eSOA that’s delivered straight to you. From there, you’re free to contact the lead and begin the presentation and enrollment process in person or over the phone that same day. You can also sit down with your clients and help them fill out the application themselves!
You can also activate direct enrollment buttons on your personal Medicareful site for qualifying carriers that you’re contracted with. Enrollments can happen in just a few clicks! Learn more about Medicareful
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Your Medicare sales process includes the same steps it always has, but these changes and the new technology available helps you get things done faster than ever. The opportunity to complete enrollments faster should be extremely satisfying for both you and your clients, and we’re really excited to hear how it makes your job easier this AEP.
Editor’s Note: This was originally published in September 2017. It has been updated to include information more relevant to the 2019 Annual Enrollment Period and the 2019 Medicare Communications and Marketing Guidelines.