Marketing Activities and Compliance
CMS is concerned with provider marketing activities for the following reasons:
- Providers may not be fully aware of all Keystone First VIP Choice (HMO SNP) benefits and costs.
- Providers may confuse the member if the provider is perceived as acting as an agent of the plan versus acting as the member's provider.
- Providers may face conflicting incentives when acting as a plan sponsor representative.
To the extent that providers can assist a member in an objective assessment of his/her needs and potential options to meet those needs, they may do so. Providers may engage in discussions with a member should he/she seek advice.