Empire: CMS Updates Review Times for Marketing Materials

CMS Updates Review Times for Marketing Materials

CMS is updating the review periods for the following:

• Provider Office Materials and Radio Scripts: The review period will change from File and Use to a 45-day prospective review.
• Enrollment Scripts and Telephonic Sales Scripts: The review period will change from a 45-day prospective review to a 5-day File and Use.

This change will be effective Monday, July 24, 2023. Materials submitted in the Health Plan Management System (HPMS) under File and Use are “accepted” and may be distributed five days after submission, provided the plan certifies the material complies with all applicable standards.

Note: CMS can always retrospectively review all materials, as well as review File and Use materials within five days of submission, to ensure compliance with applicable requirements. Based on a CMS review, they may determine that a document must be revised, or the use must be discontinued.

What does this mean for you?

Previously approved fliers used as leave-behinds in a provider office must be refiled with CMS for a 45-day review. Essentially any documents that have the potential of being left in a provider's office must be filed through the 45-day review process. Make sure you select both "flyer" and "provider office" when entering the document in HPMS if the flyer will or could potentially be left at the provider office.

The CMS Material ID (MID) for File and Use is impacted by this change. Only pieces with a MID with a 45-day review and CMS approval date will be permissible to use in a provider office.

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