Comments: 2019 Final Medicare Communications and Marketing Guidelines (MCMG)

This finalized guidance for Medicare communications and marketing guidelines has undergone a complete revision from previous years, including a major reorganization. This reorganization improves the readability and logical progression of the guidelines and is much appreciated. However, it is greatly disappointing that the guidelines do not mention the new flexibilities in Medicare Advantage (MA) and Part D and do not offer guidance for how MA sponsors should market plans with new supplemental benefits. Guidance on supplemental benefits is absolutely vital, as the risk of such benefits is that they will enable sponsors to cherry-pick beneficiaries and inappropriately steer potential enrollees. CMS has lost a valuable opportunity to establish firm guardrails to protect people with Medicare…