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CMS and MIPPA Rules

After going through another Medicare Annual Enrollment season, it is hard to believe just how many rules are listed and enforced by CMS. You can read the rules on CMS’s website, but below is a taste for some of these rules:

The following are considered “unsolicited contacts and in violation of MIPPA:”

  • Generally, use of old lists or consents to satisfy the new MIPPA rules regarding unsolicited contacts
  • Referrals of beneficiaries and/or their contact information resulting in an unsolicited contact are prohibited by the new guidance.
  • Members who are voluntarily disenrolling from a plan should not be contacted for sales purposes or be asked to consent in any formant to further sales contacts

Provider Marketing

It is “inappropriate for providers to be involved in any of the following actions”:

  • offering sales/appointment forms,
  • mailing marketing materials on behalf of plans,
  • making phone calls or steering beneficiaries, in any way, to a limited number of plans
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