CMS Marketing Updates from Cigna

These changes affect Third-Party Marketing Organizations (TPMO)s

Updated Definition of 'Marketing'

The Centers for Medicare and Medicaid Services (CMS) is updating the definition of 'marketing' to expand the content criteria to include broader mentions of particular benefits. To date, materials that mentioned widely-available benefits such as 'vision,' 'hearing,' 'dental,' and 'premium reduction' did not meet the content criteria for marketing. 

CMS is expanding the definition of marketing to include content that mentions any type of benefit covered by the plan that is intended to draw a beneficiary's attention to that plan. This means that mentions of general benefits such as 'vision,' 'hearing,' or 'dental' will be considered marketing effective July 10, 2023.

Two additional changes were made by CMS effective May 1, 2023.

Changes in HPMS

CMS recently made some changes to the Marketing module within HPMS.

• The 'Television' media type in HPMS has been expanded to include online videos. Materials submitted under this media type are subject to a 45-day review.
• A new media type titled 'Press Releases/Service Area Expansions' has been added to HPMS. Description: Releases or notices that inform beneficiaries of recent changes. This may include a change in plan service area, a press release indicating something such as an updated star rating or an IRA notice. This information is likely to be shared in a variety of formats. This category is file & use, however, only materials that include marketing content should be submitted in HPMS.

Submission of Identical Pieces by Multiple TPMOs

In instances where the same material needs to be submitted by multiple TPMOs that are contracted with different MA organizations, a unique filing ID is required. When a material that has already been filed in HPMS is filed by a different TPMO, an underscore and initials of the TPMO should be added just before the 'M' in the original material ID when submitting.

Examples:

• Original TPMO Material ID: MULTIPLAN_TPMO_DirectMail_M
• Additional TPMO Material ID: MULTIPLAN_TPMO_DirectMail_SQP_M

Additionally, in the comments section within HPMS, a note must be added explaining that the material was already filed in HPMS and the original material ID should be included. The additional underscore and initials do not have to be included on the material.

Please reach out to your Topline agency with any questions regarding how this CMS update may affect the preparation and process for future marketing.