CMS is concerned with provider marketing activities for the following reasons:

• Providers may not be fully aware of all AmeriHealth Caritas VIP Care (HMO D-SNP) benefits and costs.
• Providers may confuse the member if the provider is perceived as acting as an agent of the plan versus acting as the member's provider.
• Providers may face conflicting incentives when acting as a plan sponsor representative.

To the extent that providers can assist a member in an objective assessment of their needs and potential options to meet those needs, providers may do so. Providers may engage in discussions with a member who is seeking advice.

Acceptable and unacceptable marketing practices

Acceptable marketing practices

Providers are required to:

• Provide the names of AmeriHealth Caritas VIP Care sponsors with whom they contract and/or participate.
• Provide information and assistance in applying for the Low-Income Subsidy (LIS).
• Make available and/or distribute marketing materials supplied by AmeriHealth Caritas VIP Care.
• Refer their patients to other sources of information, such as their State Health Insurance Program (SHIP), plan marketing representatives, their state Medicaid office, their local Social Security Office, Centers for Medicare & Medicaid Services’ (CMS) Medicare website, or 1-800-MEDICARE.
• Share information with patients from CMS' Medicare website, including the Medicare and You Handbook or other documents that were written by or previously approved by CMS.

Unacceptable marketing practices

Providers must remain neutral when assisting with enrollment decisions and may NOT:

• Offer sales/appointment forms.
• Accept Medicare enrollment applications.
• Make phone calls or direct, urge, or attempt to persuade members to enroll in a specific plan based on financial or any other interests of the provider.
• Mail marketing materials on behalf of plan sponsors.
• Offer anything of value to induce plan members to select them as their provider.
• Offer inducements to persuade members to enroll in a particular plan or organization.
• Conduct health screenings as a marketing activity.
• Accept compensation directly or indirectly from AmeriHealth Caritas VIP Care for member enrollment activities.
• Distribute materials/applications within an exam room setting.

Provider affiliation information

• Providers may announce new or continuing affiliations with AmeriHealth Caritas VIP Care through general advertising, (e.g., radio, television, websites). New affiliation announcements are for those providers that have entered into a new contractual relationship with AmeriHealth Caritas VIP Care.
• Providers may make new affiliation announcements within the first 30 days of their new contract with AmeriHealth Caritas VIP Care. An announcement of a new affiliation to patients that names only AmeriHealth Caritas VIP Care may occur only once when such announcement is conveyed through direct mail, email, or phone. Additional direct mail and/or email communications from providers to their patients regarding affiliations must include a list of all plans with which the provider contracts.
• AmeriHealth Caritas VIP Care's Compliance department will secure CMS approval on any provider affiliation communication materials that describe AmeriHealth Caritas VIP Care in any way (e.g., benefits, formularies).
• Materials that indicate the provider has an affiliation with AmeriHealth Caritas VIP Care and other plan sponsors and that only list plan names and/or contact information do not require CMS approval.
• Acceptable and unacceptable marketing practices
• Provider affiliation information

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