Three Costs of Marketing Material Errors

Now that bids have been submitted and the Centers for Medicare & Medicaid Services (CMS) is in the process of finalizing their posted models (check the dates on those versions, people!), it’s time to think about material development and review.

If you are in Compliance or Product Development, chances are you have some responsibility for the material creation and review process. If you have had your hand in the process for a few years, your process has surely evolved, but some things stay the same such as:

• CMS continues to issue enforcement actions for erroneous or late materials.
• Your competitors are always on the lookout for non-compliant and misleading material, and they have no hesitation to contact your Regional Office.
• You nail down a project plan, chock full of deadlines for your creative vendor to provide you versions, for business areas to confirm accuracy of language, to deliver pieces in a staggered manner, and it never seems to stay on track.

CMS is pretty prescriptive when it comes to their model materials. The agency is going through their internal overhaul of the guidelines for Medicare Advantage, Part D, and 1876 Cost plans (released July 20 of last year), and Gorman Health Group is preparing our team to review these ever-important documents for compliance and accuracy. Each year, we support organizations to ensure materials follow CMS’ strict requirements. And with proposed changes to marketing rules (for example, disclaimers), it is more important than ever to have experienced reviewers aiding you in the process.

The costs associated with errors in this area are threefold. The first and most visible are the Civil Money Penalties (CMPs) levied on a handful of sponsors each year. If you are new to the industry (or short-sighted), you might see these CMP notices and think the cost is a drop in the bucket. That’s where I bring you to a second and less visible cost, known only to affected plan sponsors. When errors are identified, there are added internal operations costs, not only in reprint and redistribution fees, but also in staff time to correct erroneous materials in a swift, drop-everything manner.

The third cost, which I believe is the least visible but most important, is the effect this impact takes on enrollees, especially on their perception of your plan. If a member enrolled due to misinformation, this is highly disruptive. This type of issue plants serious misgivings into enrollee and caretaker minds. Materials must be clear and accurate, and with pre-enrollment packet development in mind, you only have one chance to make a first impression.

Trust me – I do not love my own plan deductibles and cost sharing, but the materials provided to me clearly outline my obligations. When I or my family members have been provided inaccurate or incomplete information, I have dropped plans at the first open enrollment period, and I have been vocal about my experience. If you are striving for retention, do not cut corners when it comes to the review of your materials.

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