Here’s my follow-up on tips how to compliantly build your own Agent or agency website. In this article I will be discussing required disclaimers for generic Medicare Marketing sites. Click here to view the CMS memo on this topic.
Required Disclaimers For Generic Agent/Agency Websites:
2. “Not connected or affiliated with any United States Government or State agency.” (This is also required by some states)
3. “Calling this number will direct you to a licensed Agent/Broker.” (Include this if your site has a contact number that directs potential clients to you or a sales team.)
These three disclaimers will satisfy passive Agent/agency websites intended for Medicare beneficiaries that are generic and do not mention specific plan names, benefits, premiums or marketing materials and do not collect any beneficiary’s information. You can read the Medicare Marketing Guidelines here — many of these disclaimers are included within that document.
Disclaimers for Sites Collecting Information for Lead Generation:
If you choose to collect potential clients’ information on your website, also ensure you include the following disclaimers for your form submissions:
1. “By submitting this form and providing this information, you agree that an authorized representative or licensed insurance agent may contact you by phone, e-mail or mail to answer your questions and provide additional information about Medicare Advantage, Part D or Medicare Supplement Insurance plans.”
2. “This is a solicitation for insurance.”
This is by no means intended to be a complete list. In fact, there are many do’s and don’ts for the content of your website in addition to just the disclaimers listed above. You can view Aetna’s recommended do’s and don’ts by clicking here. If you utilize your website for Lead generation or advertising your agency, the disclaimers and do’s and don’ts above will address many of the concerns CMS cited in their memo to Plan Sponsors.
But what If I want to list my contracted Plan Sponsors on my site and Compare Benefits?
Be prepared to submit your site for compliance review to each plan sponsor your list on your site. You must receive approval from each carrier for use of their name, logo and plan materials on your site. Your plan sponsor may also requires your site to be submitted to CMS for official review and approval. Speak with your plan sponsor’s marketing or compliance department for specific guidance on the use and publishing of their plan materials.
Build an attitude of confidence through compliance with your plan sponsors, your clients and yourself. You’ll be so happy you did when your site comes across the desk of a Plan Sponsor’s Compliance Officer, as new regulations now require CMS to audit plan sponsors and their contracted downline entities for compliance every other year.
Interested in learning more? Email me or call (800) 997 3107 to start a conversation about disclaimer and marketing guidance for sites listing and comparing plans and benefits.