The Centers for Medicare & Medicaid services (CMS) issues updated marketing guidelines on a yearly basis, referencing specific requirements with regards to assisting patients with prescription drug plan enrollment. CMS permits pharmacists to play an active, but limited role in assisting patients with their plan comparisons. In general, pharmacists need to remain objective and neutral during the enrollment process, presenting objective assessments of options that meet patient needs.
The 126-page document is quite the enjoyable read, and definitely a great way to spend Thanksgiving and Black Friday weekend. However, for those of you who may have other plans, we have assembled an overview of the Do's and Don'ts of plan comparisons for your reference!
- Make available and/or distribute plan marketing materials in common areas of the pharmacy, including the space outside of where patients wait for services or interact with Pharmacy providers and obtain medications. The foam board included in the free marketing package you receive after signing up for iMedicare is a great way to market plan comparisons for your current and prospective patients.
- Make available and/or distribute printed information comparing the benefits of all plans that are in-network and offered at the pharmacy. This information must be displayed in an objective manner. As a reminder, pharmacists are able to present an objective assessment that meets the needs of the patient. Using iMedicare, you are able to consult with the patient, and make a printout with up to three plans that are tailored to the patients needs.
- Make available and/or distribute printed information prepared by an objective third party, which compares the benefits of different plans available at your pharmacy. The third party mentioned would be iMedicare, a powerful but objective tool that allows you to compare different plans available for your patient!
Pharmacists's can NOT:
- Offer any kind of inducement to persuade, entice, or recruit a patient to enroll in a particular plan. Urging a patient to pick a particular plan that is not beneficial or suited to the patient's needs is not allowed.
- Accept compensation from plans for marketing activities of any kind. You can leave this grey area business to the insurance brokers that earn commission from chain pharmacies.
- Make any statements that suggest a plan is specially endorsed by Medicare or CMS. Plans do not and should not receive any special treatment. Your job as a pharmacist is to be as objective as possible, and help your patient pick a plan that is best for them.
- Distribute marketing materials within the Pharmacy-provider/patient counter or interaction space, other than a common area. Basically, just leave the marketing materials in the common area, not by the counter space.
- Must not mail marketing materials on behalf of any plan sponsors. You should work as an independent pharmacy. If there's any promotion to be done, it should be for your own pharmacy, not for others.
- Accept any type of Medicare enrollment applications. There is an Apply/Enroll feature in iMedicare once you reach the monthly plan comparisons. You are simply redirecting them to the government enrollment center, where they can fill out the forms using their personal information. There is no external enrollment application used in the process.
If you ever have any doubts or concerns of legal issues concerning marketing guidelines, just be Goody Two-Shoes and stay objective! With iMedicare, you'll be able to present all the plans available at your pharmacy, and help your patient shop for the best plan for them. As always, we are here to answer your questions, so give us a call at (704) 769-0540 or email us at firstname.lastname@example.org.