I lead a Medicare marketing compliance policy group for the RISE Association. We have long had the "Joe Namath" TV commercials on our radar and have published a document that we shared with the CMS Medicare Marketing Compliance group that dissects the way the leads get into the funnel from these non-compliant advertisers. The scope of the ecosystem of lead generation is a vast web of actors way beyond the regulatory reach of CMS. Unfortunately, their proposed rules only punish Med Advantage plans who are likewise unable to police where these leads originated. However, the is a silver bullet that CMS could employ if they adopt a straightforward rule that requires every lead received in the upstream channels to carry a CMS marketing approval code. This would effectively choke off these outlaw advertisers and others operating boiler room call centers in Pakistan that profit from illegal sales and marketing tactics beyond the reach of all Med Advantage companies and CMS. That simple fix would kill the Joe Namath leads that are sold to brokers that unknowingly flip unwitting members of Med Advantage plans into other health plans without their awareness and consent.
I have always been a fan of yours, even when our views differ. The reason for that is that you care a lot and you are well-informed, but we come to differing conclusions on certain topics. My skin is particularly thin around the Medicare Advantage program as a career MA plan executive. Nonetheless, the flies in the ointment you point out are not imaginary, but I believe the underlying causes and the motivation (having sat on that side of the table) are quite different from your opinions.
I would very much like to have a dialogue and exchange of views, if you would like. I am reluctant to say I would change your ultimate opinions, but I hope I could shed some light around the source of some of these important flaws that undermine credibility and, in the end, the supportability of the Med Advantage experiment.
Kind regards and much encouragement from one retired guy to another,
I lead a Medicare marketing compliance policy group for the RISE Association. We have long had the "Joe Namath" TV commercials on our radar and have published a document that we shared with the CMS Medicare Marketing Compliance group that dissects the way the leads get into the funnel from these non-compliant advertisers. The scope of the ecosystem of lead generation is a vast web of actors way beyond the regulatory reach of CMS. Unfortunately, their proposed rules only punish Med Advantage plans who are likewise unable to police where these leads originated. However, the is a silver bullet that CMS could employ if they adopt a straightforward rule that requires every lead received in the upstream channels to carry a CMS marketing approval code. This would effectively choke off these outlaw advertisers and others operating boiler room call centers in Pakistan that profit from illegal sales and marketing tactics beyond the reach of all Med Advantage companies and CMS. That simple fix would kill the Joe Namath leads that are sold to brokers that unknowingly flip unwitting members of Med Advantage plans into other health plans without their awareness and consent.
Hi, Merrill,
I have always been a fan of yours, even when our views differ. The reason for that is that you care a lot and you are well-informed, but we come to differing conclusions on certain topics. My skin is particularly thin around the Medicare Advantage program as a career MA plan executive. Nonetheless, the flies in the ointment you point out are not imaginary, but I believe the underlying causes and the motivation (having sat on that side of the table) are quite different from your opinions.
I would very much like to have a dialogue and exchange of views, if you would like. I am reluctant to say I would change your ultimate opinions, but I hope I could shed some light around the source of some of these important flaws that undermine credibility and, in the end, the supportability of the Med Advantage experiment.
Kind regards and much encouragement from one retired guy to another,
Kevin Mowll
kevmowll@outlook.com