A Simple Guide to Marketing During Medicare Enrollment Periods- AEP, SEP, and OEP

Jun 23, 2021 | AEP, Agents, Insurance, Lead Generation, Medicare Leads

With so many rules and regulations, Medicare enrollment periods and the guidelines associated with them can be difficult to navigate. Currently, there are four periods in which a client can enroll in a Medicare plan or change their current plan. These are the Initial Enrollment Period (IEP), Annual Enrollment Period (AEP), Open Enrollment Period (OEP), and Special Enrollment Period (SEP). Each enrollment period has special requirements and restrictions for both the agent and the client.  

Initial Enrollment Period for Medicare 

The IEP is specific for each person as it depends on their birthday. For people who are eligible for Medicare, the Initial Enrollment Period begins three months before their 65th birthday, includes their birthday month, and ends three months after their birthday, making their IEP a 7-month time period. During this time, seniors are eligible to sign up for Part A and/or Part B plans. Retired seniors who are receiving government benefits (such as social security) are automatically enrolled in Medicare Part A without paying a premium. Employed seniors or those who are not yet receiving other government benefits will have to sign up manually. Medicare Part B requires the beneficiary to pay a premium and is closer to the traditional idea of health insurance. There are penalties for late enrollment for both Part A and Part B respectively.  

Annual Enrollment Period for Medicare 

AEP officially lasts from Oct. 15-Dec.7. However, seasoned Medicare agents and brokers know that the preparation for AEP can begin as early as June. AEP is the busiest time of year for Medicare agents, so it is important to have a proper marketing plan in place. According to rules put in place by the Centers for Medicare and Medicaid Services (CMS), anyone selling Medicare or Medicare Supplements cannot directly advertise the AEP until Oct. 1. With this date being only two weeks before the AEP begins, finding new business during such a competitive time may seem difficult or even impossible. However, there are ways to warm up the market before any official marketing campaign due to guidelines by the CMS that differentiate between agent-to-client “communications” and “marketing” in the Medicare Communications and Marketing Guidelines (MCMG). 

“Communications” are defined as… 

Activities and use of materials to provide information to current and prospective enrollees. This means that all activities and materials aimed at prospective and current enrollees, including their caregivers and other decision makers associated with a prospective or current enrollee, are “communications” within the scope of the regulations at 42 CFR Parts 417, 422, and 423.” 

“Marketing” is defined as… 

A subset of communications and includes activities and use of materials by the Plan/Part D sponsor with the intent to draw a beneficiary’s attention to a plan or plans and to influence a beneficiary’s decision-making process when selecting a plan for enrollment or deciding to stay enrolled in a plan (that is, retention-based marketing). Additionally, marketing contains information about the plan’s benefit structure, cost sharing, measuring, or ranking standards.” 

It is recommended to begin communication efforts around mid-Sept. in order to prepare current or prospective clients for AEP. However, it is important that agents and brokers understand what is and isn’t allowed in advertisements before Oct. 1.  

According to the MCMG, communications and marketing are distinguished by “intent” and “content.” 

Here is how the MCMG defines marketing intent and content… 

“Intent – the purpose of marketing activities and materials is to draw a prospective or current enrollee’s attention to a plan or group of plans to influence a beneficiary’s decision when selecting and enrolling in a plan or deciding to stay in a plan (retention-based marketing).  

Content – based on the exclusions in the definition of marketing and marketing materials and the type of information that would be intended to draw attention to a plan or influence a beneficiary’s enrollment decision, marketing activities and materials include:  

  • Information about benefits or benefit structure; 
  • Information about premiums and cost sharing; 
  • Comparisons to other Plan(s)/Part D sponsor(s); 
  • Rankings or measurements in reference to other Plan(s)/Part D sponsor(s); or 
  • Information about Star Ratings”

In other words, advertisements for Medicare will be more vague before Oct. 1. However, there are also guidelines for the marketing period of AEP. For example, the MCMG states that marketing materials must state which plan year is being discussed in the ad (although current and prospective years can be marketed simultaneously), and brokers can only market their plans to eligible beneficiaries for valid enrollment.  

Additionally, sales and educational events may or may not need to be registered with each carrier in order to remain within the marketing guidelines, visit cms.gov for more information.  

Marketing also includes: 

  1. Discussing rates, benefits, or options for the next year over a phone call or at an appointment  
  1. Holding events with the goal of sales or marketing in which options for the next year will be discussed 
  1. Completing an enrollment application 

Additionally, the MCMG state that agents and brokers may not use door-to-door solicitation, approach potential enrollees in common areas unsolicited, or use telephonic solicitation. There are many other specific guidelines listed for agents and brokers to adhere to. For example, at sales or marketing events, refreshments and light snacks may be provided, but no item can be provided that may reasonably be considered a “meal.” However, meals may be provided at communications events.  

Open Enrollment Period for Medicare 

OEP, which lasts from Jan. 1 to March 31, is more restrictive than AEP due to the fact that it is considered a secondary option for beneficiaries who are unhappy with the plan they chose during AEP.  

Because of this, there are many marketing regulations when discussing OEP, and OEP cannot be discussed directly in advertisements or marketing strategies.  

Agents CAN:  

  • Conduct marketing activities that focus on other enrollment periods only 
  • Send marketing email advertisements and materials if an eligible person makes a proactive request. 
  • Market to age-ins who have not yet selected a plan 
  • Provide information on OEP through a call center at the beneficiary’s request.  
  • Market to age-ins by dual-eligible and LIS beneficiaries by five-star plans.  

Agents CANNOT: 

  • Target Medicare Advantage or Part D enrollees during OEP knowingly. 
  • Send unsolicited marketing advertising materials during OEP. 
  • Use OEP as an opportunity to make more sales. 
  • Contact previous enrollees who chose a new plan during AEP 

Special Enrollment Period for Medicare 

SEP is reserved for special circumstances. Whether there is a global pandemic or a client moves into a new zip code, there are many instances in which a client may be eligible for a special enrollment period. 

A client may be eligible for SEP if…  

1. They change where they live 

If a client moves outside of their plan’s service area to a new address, moves to a new address inside their plan’s service area that provides more or better options, returned to the United States after living in a different country, moved into, moved out of, or lives in an institution (such as a nursing home), or were released from jail, they are eligible. 

2. They lose their coverage 

If a client becomes ineligible for Medicaid, left their employer or union-supplied coverage, involuntarily lose coverage worse than Medicare or other coverage and is no longer eligible, left a Medicare cost plan that provided drug coverage, or canceled coverage in a program such as Program of All-Inclusive Care for the Elderly (PACE), they are eligible.  

3. They have a chance to get other coverage 

If a client has a chance to enroll in a new plan through their employer or union, is enrolling in in a plan as good as Medicare prescription drug coverage, or is enrolled in PACE, they are eligible.  

4. The client’s plan changes due to Medicare 

If Medicare makes a sanction because of a problem with a client’s plan that affects them or Medicare terminates the client’s plan’s contract, they are eligible.  

5. A different special circumstance occurs 

If a client is eligible for both Medicaid and Medicare, qualifies for extra support paying for Medicare drug coverage, loses SPAP eligibility or is enrolled in a state pharmaceutical assistance program, dropped a Medigap policy the first time they joined a Medicare Advantage plan, has a disabling or severe condition that is addressed by a Medicare Chronic Care Special Needs Plan (SNP), is enrolled in an SNP but no longer has a condition that qualifies for an SNP, was wrongfully advised by a federal employee to join a plan or choose not to join a plan, was not advised that other private drug coverage was not as beneficial as Medicare (or credible) drug coverage, or was not properly told that they were losing private drug coverage that was as good as Medicare drug coverage, they are eligible.  

In 2021 specifically, due to the coronavirus pandemic, the Centers for Medicare and Medicaid services have extended access to the SEP until August 15.  

When and How Should I Advertise Medicare to My Clients? 

AEP 

It is possible for agents to indirectly let their clients know AEP is coming up while still following MCMG guidelines. This tactic of “warming up the market” is widely used, but it is important to reference what is defined as “marketing” versus “communications.”  

Here are two examples of advertisements related to AEP:  

  1. A,B,C Health is now offering Medicare Advantage Coverage in Narnia County, call us today for more information!  
  1. A,B,C Health offers low costPremium Plans with Dental coverage in Narnia County 

Which one is marketing, and which one is communication? According to the CMS, No. 1 would be communication, while No. 2 would be marketing. No. 1 does not attempt to persuade the client to purchase any specific plan, while No. 2 attempts to convince the client to buy a plan from them by including the rate and specific benefits. Remember that marketing is still allowed starting Oct. 1, but beginning an awareness or communications campaign before then may be beneficial for brokers and agents considering the competitive nature of AEP.  

Begin planning your AEP marketing campaign here  

OEP 

OEP should not be mentioned in any advertising or contact with any eligible enrollee unless the communication follows the OEP guidelines listed above. If a potential enrollee specifically requests information about OEP they should be directed to the call center.  

SEP 

Agents are not allowed to encourage clients to enroll in lower-rated plans during AEP under the impression that they can enroll in a higher-rated plan during SEP or OEP. Agents also cannot inform beneficiaries who are not happy with their plan, and have lower-rated plans, that they are eligible to request an SEP and enroll in a higher-rated plan according to MCMG section 40.6.2. In fact, SEP is the most limited enrollment period as far as advertising goes.  

Although this article is not an all-inclusive informational guide, the basic steps for your Medicare marketing campaign should rely on these guidelines. For more information on AEP, OEP, IEP, SEP, or Medicare, contact us today 

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