![]() ![]() Does this requirement to record calls apply to both inbound and outbound calls? It must be ensured that all calls between a TPMO and a beneficiary are recorded. Is it now a requirement for an agent to record all calls with enrollees, even calls that are outside the scope of the chain of enrollment? ![]() Captive agents fall under the definition of a TPMO as defined in 42 CFR – 422.2260 and 423.2260. Does the requirement to record calls pertain to captive agents? This requirement applies to all organizations and individuals that fall under the definition of TPMO as defined in 42 CFR – 422.2260 and 423.2260. TPMOs may be a first tier, downstream or related entity.Įxamples of First Tier, Downstream, and Related Entities (FDRs):ĭoes this new requirement to record calls apply only to call centers? The definition of TPMO includes all organizations and individuals, including independent agents and brokers, who are compensated to perform lead generation, marketing, sales, and enrollment related functions as a part of the chain of enrollment. The requirement applies to all organizations and individuals that fall under the definition of Third-Party Marketing Organization (TPMO) as defined in 42 CFR – 422.2260 and 423.2260. This includes calls that are part of the chain of enrollment into a Medicare Advantage or Part D Plan (the steps taken by a beneficiary since becoming aware of a Medicare plan or plans to making an enrollment decision), as well as post-enrollment telephonic discussions. When did Medicare requirements start?īy October 1 st 2022, you had to be prepared to record all calls with potential Medicare beneficiaries (prospects), however, calls with current Medicare beneficiaries have to be recorded in their entirety as of January 1 st, 2023, as it is the date on which policies are renewed. Examples included beneficiaries being told that if their medication was not on the formulary, the doctor could tell the plan and the plan would simply add it or incorrectly stating that “nothing would change” when beneficiaries asked if their current health coverage would stay the same. The agents failed to provide the beneficiary with the necessary information or provided inaccurate information to make an informed choice for more than 80 percent of the calls reviewed. In response to a significant increase in marketing-related complaints, CMS staff reviewed numerous recordings of calls from different marketing entities, including individual agents and brokers, as well as larger call centers. These rules were designed to address complaints of inappropriate marketing that CMS received from beneficiaries and their caregivers. If the prospect or member does not want to be recorded, you should stop the recording and the call.Face to face virtual interactions on platforms like Zoom need to be recorded.You must be able to provide call recordings related to specific beneficiary interactions upon request. Every single call, in which prospects and current members participate, must be recorded and stored in a HIPAA compliant manner for 10 years.The wording of the rule references “marketing” calls, but the National Association of Health Underwriters (NAHU) confirmed that CMS interprets “enrollment” as “marketing.” Online applications that agents walk through with their clients are also subject to recording.” Medicare recording calls: Helpful Reminders “The recording requirement applies to all agents who enroll beneficiaries into new plans, whether they are current or new clients. This rule was slated to go into effect on October 1, 2022. Part of these CMS call recording requirements 2023 is the agents’ obligation to record and store all Medicare and Medicaid “marketing” calls. On May 9, 2022, the Center for Medicare & Medicaid Services (CMS) announced a new ruling called the CMS Final Rule 2023.
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