HFG Compliance Review Submission
Heartland Financial Group & OneLife America are committed to strict compliance adherence to CMS communications, marketing regulations and individual MAO marketing guidelines. All marketing materials that will be used for the general public must adhere to specific communication requirements and must be submitted for review and approval prior to public dissemination.
General Guidelines to follow:
• The use of carrier logos is strictly prohibited unless you have carrier approval in writing. Most MAO’s require the marketing material, the setting used, and the intended audience be submitted for review and approval of marketing materials. The materials should be submitted to HFG/OLA compliance no later than 30 days prior to its intended publication date.
• All Medicare Part C marketing including generic marketing that list any plan benefits E.g., D/V/H, OTC, Food Cards, Fitness Memberships, Plan Premiums, or copays require MAO/CMS approval per the October 8, 2021, guidance released by CMS. The examples above are not a complete listing and are for illustrative purposes only. A good rule of thumb to follow is if the marketing piece is intended to drive enrollment for Medicare Part C or list any benefit not covered by Original Medicare approval prior to publication and use is required. However, HFG/OLA requires all marketing material to be submitted to the HFG/OLA Compliance Department prior to use to ensure it meets all state, federal, and regulatory guidelines.
• Scripts in-bound/out-bound must be submitted prior to implementation for approval. If a CMS approval number currently exist, please submit the scripting and Lead Plan Sponsor (LPS) communications with approval/guidance on its intended usage for review.
• All printed sales presentations must be approved prior to use.
While the above is not intended to satisfy every example you may face, it is intended as general marketing guidance to help you remain compliant, and within MAO/CMS Medicare Communications and Marketing Guidelines. The guidance set forth in this document is subject to change as policy, communications, technology, and industry marketing practices evolve.