Dos and Don’ts of Seminars

Policy Number: SLS-026

PURPOSE:

This policy exists to ensure Care N’ Care (CNC) seminars are compliant with the guidelines outlined by the Centers for Medicare & Medicaid Services (CMS) by adhering to the policies outlined herein as well as related policies and procedures.

DEFINITIONS:

Centers for Medicare and Medicaid Services (CMS): The federal agency within the Department of Health and Human Services that administers the Medicare program.

Medicare Managed Care Manual – Chapter 3 Medicare Marketing Guidelines –  Manual written and published by CMS for use by Medicare Health Plans and Agents to use to ensure compliance in regards to marketing to potential plan enrollees. It sets guidelines for communication and enrollment for these entities.

Sales Agent – Licensed insurance agents that are employed by CNC and/or external agents who are licensed, contracted and are certified to sell CNC Medicare Advantage Plans.

POLICY:

CNC follows the Centers for Medicare & Medicaid’s Services (CMS) requirements contained in the Medicare Managed Care Manual – Chapter 3 Medicare Marketing Guidelines and in the applicable regulations, in regard to seminar activities, to ensure that they do not mislead, confuse, or misrepresent the organization.

CNC is committed to ensuring that all CNC Seminars follow the guidelines set forth by the Centers for Medicare and Medicaid Services (CMS) and in CNC policies when representing CNC plans and products. All CNC employees or sales agents delivering or assisting in the delivery of seminars must follow the do’s and don’ts for seminars. Failure to comply with the do’s and don’ts will result in re-training and/or removal of employee(s) or sales agent(s) from seminar participation.

PROCEDURE:

Seminar participants must review the Medicare Managed Care Manual – Chapter 3 Medicare Marketing Guidelines and related content for the execution and delivery of seminars. In addition, CNC staff must review related Policies and Procedures (P&P) to ensure associated P&Ps are adhered to within the delivery of seminars.

  1. Sales Agents must review Do’s and Don’ts.
    Do:
    • Understand roles and responsibilities
    • Work with sales support to adequately prepare materials and presentations in advance of the meeting
    • Complete required CNC compliance, sales training and certifications before conducting seminars
    • Report any issues and results to Senior Manager of Sales
    • Complete required seminar documentation
    • Comply with the Medicare Managed Care Manual – Chapter 3 Medicare Marketing Guidelines
    • Provide proper support to ensure all attendees understand the purpose of the seminar

Don’t:

    • Deviate from prepared materials
    • Offer opinions or personal beliefs that may sway attendees
    • Present content using scare tactics
    • Misrepresent CNC or the content provided by CNC
    • Offer other programs or services not approved
    • Speak of other plans or agents in a negative light
    • Misrepresent plan’s Star Rating
    • Sign up members outside of the appropriate enrollment periods
    • Use Superlatives such as “best” or “only” when describing the plan
  1. Senior Manager of Sales or other sales staff to conduct an internal secret shopping exercise for each Sales Agent conducting seminars
  2. If Sales Agent is not adhering to do’s and don’ts, he/she is removed from presenting at seminars until retraining is completed.
  3. If a Sales Agent must complete retraining more than two (2) times within a selling season, they are removed from presenting at seminars for the remaining season.
  4. Each Sales Agent will be provided an Optional Sign In Sheet or will have to furnish one as well as a Seminar Report that will need to be filled out or referenced for every event.

QUALITY ASSURANCE:

  • Sales Leadership to promptly review any deficiencies identified
  • Retraining conducted with sales agent prior to conducting the next seminar
  • Adhere to cross-referenced policies and procedures
  • Required documentation must be complete within 48 hours of retraining