Lead Quantification

CMS Approval and Compliance: Navigating Medicare Open Enrollment

Buying or selling Medicare Advantage Leads During Open Enrollment? Avoid legal risks with non-compliant leads. Here’s what you need to know about the CMS Compliance Regulations.

PX has made CMS Compliance Certification our highest priority, and we want to help all our sources and Medicare Advantage Plan advertisers to do the same with ease and confidence.  

CMS Compliance Regulations look a little different this time around. Here are some of the main points you need to know to ensure a successful lead acquisition for AEP:

Certification: Get Certified ASAP! 

  • Sources not only have to be CMS compliant, but they also must be certified through the CMS website and receive a SMID/DIN number. 

  •  The SMID/DIN number MUST be displayed at the bottom of the generating site’s homepage

Adherence to Compliance: Compliance must be absolute. There is no asking for forgiveness here. 

    • CMS is going to take legal action against the lead source and the insurance company responsible for the sale of any Medicare Advantage Plan that is generated from a lead source that is not a CMS Certified Source.  

    • The following disclaimer should be available near the TCPA language on all lead-generating sites: “We do not offer every plan available in your area. Any information we provide is limited to those plans we do offer in your area. Please contact Medicare.gov or 1-800-MEDICARE to get information on your options.” 

    • Insurance companies are going to rely heavily on the discretion of their legal teams. Any association with a non-compliant sale will most likely result in the dissolution of their partnership.

The PX Approach  

  • Be Prepared: Sources for Medicare Advantage Open Enrollment Must Be Vetted.
    • All sites must pass through PX Compliance before September 1, 2023, to be available for Medicare Advantage campaigns

    • All sites must provide sample creatives before September 1, 2023, to be available for Medicare Advantage campaigns
    • All CMS Paperwork and Carrier Approvals Must Be Submitted by September 15th, 2023
  • All call publishers must provide up-to-date scripts before September 1, 2023, to be available for Medicare Advantage campaigns. All publishers and buyers must complete PX’s best practices checklist before September 1, 2023, to be opened to Medicare Advantage campaigns.

  • Put Safety Measures in Place: Using the PX Platform and Team!
    • Prior to open enrollment, all PX site details will include a field for SMID/DIN certification numbers.  

    • Buyers will be able to filter and block leads on the CMS SMID/DIN field.  

    • Buyers will be able to request creatives and scripts per source upon request prior to Open Enrollment Launch by contacting compliance@px.com.  

    • Prior to launch, PX will send out both buyer and publisher checklists to all who have campaigns set up to ensure everyone is ready to go.  

CMS’s added checks and balances for Open Enrollment may seem cumbersome, but preparation and continued vigilance will ensure success. PX is committed to making that dream of success a reality for both sources and Medicare Advantage providers.  

Let PX help you navigate your way to compliant success during this year's Open Enrollment.  



Ready to take the lead?


Similar posts

Don't miss out on new insights!

Be the first to know about new lead acquisition trends and technology.