CHIP/Medicaid Managed Care Marketing Policies Overview. August 4, 2010

Transcription

1 CHIP/Medicaid Managed Care Marketing Policies Overview August 4, 2010

2 Purpose Provide accurate and consistent application of the Marketing Policies as they relate to CHIP and Medicaid Managed Care Programs in the State of Texas. Establish fair Marketing practices for all MCOs and/or their Agents, in order to prevent unfair Marketing practices and ensure Marketing plan and Marketing Materials are consistent with HHSC s Marketing campaign. Provide continuous Marketing education through periodic updates and training on revised or new Marketing Policies and Procedures. 2 Establish procedures for investigating and processing Marketing violations and imposing appropriate remedies, as applicable.

3 MP General Provisions Requirements: Submit all Marketing and Member Materials for review and approval prior to use. Allow 15 business days. All Marketing Materials must be written at a reading level not higher than 6 th grade. Reading level must be provided. All Materials must be submitted with a form number developed by the MCO on the bottom left hand corner. This needs to be included on material when distributed. See UMCM 1.1 3

4 MP General Provisions (continued) MCO must use the DADS Translation Unit to translate Medicaid Marketing Materials into Spanish. MCOs may translate their CHIP Marketing Materials. What if an item is going to be used for both Medicaid and CHIP? HHSC has established a communications tool kit that is posted on the Medicaid/CHIP page and referenced in the UMCM for preparation of client materials. It provides recommended terms for client materials 4

5 MP General Provisions (continued) 5 What requires HHSC approval? Marketing Materials Member Materials Provider Manuals Information to be used on MCO website Print media Television or radio storyboards or scripts Member participation materials What doesn t require HHSC approval? Health-related materials with no program information i.e. American Heart Association Information for providers (except contract) Storyboards or scripts if the advertisements are used as a means of developing name recognition, and no reference is made to the CHIP or Medicaid Programs.

6 MP 2.00 Prohibited Marketing Practices Making Giveaways conditional based on enrollment with the MCO; Charging members for goods or services distributed at events, or for accessing the MCO s website; Influencing enrollment in conjunction with the sale or offering of any private insurance Medicare Member Materials that references Medicaid or STAR+PLUS must be submitted for review and approval Posting MCO-specific, non-health related materials or banners in provider s offices 6

7 MP 2.00 Prohibited Marketing Practices (continued) Using Marketing Agents who are paid solely by commission; Using terms that would influence potential members to contact the MCO, rather than MAXIMUS for enrollment; Purchasing or otherwise acquiring mailing lists from third party vendors, or for paying HHSC contractors or sub-contractors to send plan specific materials to potential members; Referencing the commercial component of the MCO in any of its CHIP or Medicaid Managed Care Marketing Materials; 7 Discriminating against a Member or potential Member because of race, creed, age, color, religion, natural origin, ancestry, marital status, sexual orientation, physical or mental disability, Health Status or existing need for medical care;

8 MP 2.00 Prohibited Marketing Practices (continued) Making false, misleading or inaccurate statements relating to services or benefits of the MCO or the CHIP or Medicaid Managed Care Programs, or relating to the providers or potential providers contracting with the MCO; Inducing or accepting a Member s enrollment or disenrollment; Portraying competitors in a negative manner; Making any assertion or statement (orally or in writing) that the MCO is endorsed by the CMS, a federal or state government agency, or similar entity; or 8 Using Spam

9 MP-2.00 Prohibited Marketing Practices Common Questions Marketing in or around public assistance or eligibility offices What is considered a public assistance or eligibility office? Assisting with enrollment form or influencing MCO selection What is the difference between an application and an enrollment form? 9

10 MP Reporting Alleged Marketing Violations 10 HHSC will investigate all reported Marketing violations and take appropriate action. 1. Submit completed complaint form to your Health Plan Manager 2. HHSC will send acknowledgement within 5 days 3. Investigation will be completed within 30 days, if no extenuating circumstances. 4. Complainant is notified after HPM takes appropriate action. Complainant will be advised if the allegation is in or out of compliance. If sanctions are warranted, the HHSC Contract allows liquidated damages up to $1,000 per incident of noncompliance.

11 MP Policies Related to Program Providers Provider contract or Provider Manual is required to state that Providers will comply with Marketing Policies and Procedures. Providers may provide and assist with completion of the application. Providers may not assist with the enrollment form. Providers may inform patients of the MCO(s) and program(s) in which they participate. 11

12 MP Policies Related to Program Providers (continued) Providers may not recommend or provide incentives for patients to select one MCO over another. Providers must display stickers for all contracted MCOs who request and provide stickers Providers must distribute and/or display Health-Related Materials for all contracted MCOs. What if the Provider does not want to display stickers or materials provided by an MCO? 12

13 MP Policies Related to Program Providers (continued) MCOs may not provide incentives or giveaways to Providers for the purpose of distributing them to Members or potential Members. MCOs may not allow Providers to solicit enrollment or disenrollment in an MCO, or distribute MCO-specific materials at a Marketing activity (This does not apply to health fairs where providers do immunizations, blood pressure checks, etc. as long as the provider is not soliciting enrollment or distributing plan specific MCO materials.) MCOs may not conduct member orientation in Common Areas of Providers offices. Private conference rooms can be used. 13

14 MP Use of Logos Marketing Materials related to the CHIP and Medicaid Programs for potential members must include the appropriate program logo. All logos can be obtained at: 14

15 MP Website/Internet Website must include general information about its health plan, provider network, customer services, and complaints and appeals process. Website must provide access to a Provider Directory, with designation of open vs. closed panels. Provider information needs to be updated at least twice per month. Home Health Ancillary providers must be included, with an indicator of Pediatric services. Although look-up by zip code is an option, the entire directory must also be available. 15 Website must meet requirements outlined for print and electronic media (readability, Spanish translation, logos, approval by HHSC, 6 th grade reading level, etc.).

16 MP Print Media Print Media includes any displayed or published advertisement intended to be read by CHIP and/or Medicaid Program Members or potential members. MCO must advise HHSC of when and where publications and displays will appear. MCO may send outreach materials, re-enrollment notices, and non-marketing correspondence to Members. MCO may send plan specific materials to potential Members at the potential Member s request. Terms such as choose, pick, join, etc. are allowed in Marketing Materials as long as MAXIMUS or the local community-based organization s telephone number is included. 16

17 MP Electronic Media (TV/Radio) MCO must provide HHSC with a schedule indicating when the electronic media advertisements will be aired, including date and station. TV storyboards must contain the appropriate logo, unless a waiver is granted. Storyboards or scripts do not require HHSC approval if the advertisements are used as a means of developing name recognition, and no reference is made to the CHIP or Medicaid Programs. 17

18 MP Cold Call Marketing Cold Call Marketing is strictly prohibited. This includes: 1. Unsolicited personal contact with a potential enrollee, such as door-to-door or telephone marketing. 2. Marketing activities at an employer-sponsored Enrollment Event where employee participation is mandated by the employer. ( If employee participation is not mandated by the employer, the MCO must notify its Health Plan Manager regarding the invitation and must provide information about the Marketing activities the MCO will conduct at the particular business). 3. Any other personal contact with a potential Member if the potential member has not initiated the contact with the MCO. MCO may only conduct telephone marketing during incoming calls from potential members. MCO may return calls when requested by the caller. 18 All inquiries regarding enrollment must be referred to MAXIMUS.

19 MP Direct Mail Marketing Direct Mail Marketing to potential Members is prohibited. However, the MCO is permitted to respond to verbal or written requests for information made by potential Members. Direct Mail Marketing does not include plan specific, outreach materials, re-enrollment notices, and non-marketing correspondence sent to current Members. 19

20 MP Giveaways MCO may distribute giveaways valued under $10.00 to potential Members. Giveaways valued over $10.00 may be distributed to current Members. Giveaways are not required to include the program logo. Giveaways must be submitted to HHSC for approval unless: 1. The information included on the Giveaway is limited to the MCO s name or initials, and its phone number or website address; and 2. The Giveaway makes no reference to the CHIP or Medicaid Program in any way. 20

21 MP Giveaways (continued) MCOs are allowed to accept items from third party sources the same dollar limits apply. The MCO is allowed to adhere its plan sticker to third party items. 21

22 MP Member Participation in MCO Activities MCOs may solicit its current Members for participation in MCO activities. MCO may provide incentives and giveaways to encourage Member attendance. MCO must maintain evidence that the Member has been informed that any monetary compensation received must be reported to OES/SSA and that it could affect the Members Medicaid eligibility. 22

23 MP Periodic Surveys MCOs may survey their former and current Members. Surveys may not be used for the purpose of soliciting the reenrollment of former Members. Incentives or Giveaways may be used to encourage current Members to participate in the survey. They may not be used to encourage former Member s participation. 23

24 MP Sponsorship/Donations MCO is not allowed to make charitable contributions or donations from the CHIP/Medicaid Managed Care Program funds. MCO may make charitable contributions or donations from its general revenue, earned income funds, or other corporate income funds, as long as the MCO does not report it as an Allowable Expense. 24

25 MP Medicaid Enrollment Events Enrollment Events are forums to provide enrollment information, educating potential Members regarding Medicaid Managed Care and distributing Application forms for Children s Medicaid/CHIP. 25

26 MP Medicaid Enrollment Events (continued) These are set up by MAXIMUS, which will fax a notification form to MCOs prior to the event. Exclusive Enrollment Events are run by MAXIMUS, and specifically excludes MCO participation. MCOs are allowed to conduct plan recognition through Marketing activities. MCO may have MCO-specific Marketing materials, Provider Directories, and Member Handbooks available at the Event. Application forms and Comparison Charts will be made available during the Enrollment Event. 26 The number of MCO Marketing Representatives allowed at the Event will be limited based on the anticipated attendance.

27 MP Other Events MCOs may organize events and/or participate in events relating to: 1. MCO recognition; 2. Health education; 3. Program education; 4. Marketing; and/or 5. Distribution of Program Application 27

28 MP Other Events (continued) MCO must provide MCO Notification of an Other Events to MAXIMUS at least 2 days prior to the Event. Fax to: There is no limit to the number of MCO representatives during Other Events. MCO may choose to invite other MCOs in the Service Area to participate in the Other Event. The Event may become an Enrollment Event if all MCOs are invited. 28

29 *Pending STAR+PLUS Medicare Advantage What is Medicare Advantage? Medicare beneficiaries are given the option to receive their Medicare benefits through private health insurance plans, instead of through the original Medicare plan (Parts A and B). These programs are known as Medicare+Choice or Part C plans. These Medicare Advantage Plans are health plan options that are part of the Medicare program. If a member joins one of these plans, they generally get all of their Medicare-covered health care through that plan. 29

30 *Pending STAR+PLUS Medicare Advantage (continued) All Marketing Material containing information related to the HMOs Medicaid/Medicare health plan, must be reviewed and approved by CMS prior to HHSC s review. Advertising and Explanatory Materials are considered Marketing instruments. Marketing Materials, May use the term Medicaid/Medicare approved May not use misleading terms such as Sponsored by Medicaid/Medicare, etc. 30 Medicare Marketing Guidelines are silent to Spamming, however, Internet policy applies.

31 *Pending STAR+PLUS Medicare Advantage (continued) Medicaid/Medicare Advantage HMOs are allowed to market Dual Eligible members. HMOs are allowed to distribute Medicare Advantage marketing materials at Medicaid (STAR+PLUS) Enrollment Events. Medicare Advantage STAR+PLUS HMOs are prohibited from marketing their STAR+PLUS product outside of their defined STAR+PLUS Service Area, even if the Medicare product is approved state-wide). Exception: Unless such advertising is unavoidable (i.e., TV, or radio broadcast). 31

32 Questions If you ever have a question that is not addressed by the Marketing Policies and Procedures, your Health Plan Manager can provide clarification. 32

33 My signature means that I have received the Tejas Behavioral Health Services Training: CHIP/Medicaid Managed Care Marketing Policies Overview and I acknowledge that it is my responsibility to read and comply with the procedures and policies set forth. Print Name (Clearly) Signature Date (Required)