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Health Care Communiqué: Q3 – 2009
Final Marketing Guidelines
On August 7, 2009 CMS released a new Chapter 3 - Marketing Guidelines. The requirements were effective on the same day that they were released. While CMS has released many memorandums on this topic, this is the first update to the chapter in over three years.
The new guidelines include the topics that have been covered in previously issued memorandum, including the MIPPA requirements. The topics range from broker/agent compensation to disclosure requirements to new material requirements.
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CMS Audit
One of the first steps in a CMS audit is a request to the plan to disclose all delegation relationships.. Many organizations elect to contract with business partners to perform certain functions that otherwise would be the responsibility of the organization to perform, including management and provision of services. CMS allows delegation of responsibility, but not accountability.
When delegation exists, CMS' focus is not directly on the performance of the delegated entity but on how the plan oversees the functions that have been delegated. CMS may request Universes and review cases or files handled by the delegated entity. A CMS audit should not uncover anything that the plan is not already aware of or is not already working with the delegated entity to get corrected.
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