Make the Most of This Medicare OEP

Well, if you’re like me, you were excited to hear that the Medicare Advantage open enrollment period (OEP) is back for 2019. As of January 1, 2019, an individual enrolled in an MA plan has the opportunity to make a one-time election to switch to another MA plan or Original Medicare before March 31, 2019. During this new OEP, individuals also have the ability to add or drop Part D coverage.

However for 2019, CMS is prohibiting any direct advertising about this period. How crushing! Section 40.7 of the Medicare Communications and Marketing Guidelines (MCMG) states:

“Plans/Part D sponsors are prohibited from knowingly targeting or sending unsolicited marketing materials to any MA enrollee or Part D enrollee during the continuous Open Enrollment Period (OEP) (January 1 to March 31). ‘Knowingly’ takes into account the intended recipient as well as the content of the message.”
Centers for Medicare & Medicaid Services – Medicare Marketing Guidelines

You are a challenger brand. You can’t afford to sit back. What if I told you there were things that you can be doing right now to grow your membership during OEP while staying compliant with CMS regulations? Here are a few suggestions to get you started:

1. Implement paid search advertising
   A recent Deft Research study found that 73% of those who switched insurers during AEP used the internet to research and compare plans. Implementing paid search advertising during OEP will help attract potential switchers to your plan. But just a reminder that your ads cannot reference the OEP or call out to “switchers.” Instead have your ads address the key drivers for switchers to choose your plan, such as plan ratings, low plan premiums and/or network of providers.
2. Increase your age-in marketing presence
   CMS regulations allow you to “conduct marketing activities that focus on other enrollment opportunities” during OEP. Hopefully you are starting your year off with an age-in campaign that includes digital marketing. While your messaging will be focused on those aging into Medicare, your presence will attract potential switchers during OEP.
3. Promote your dual-eligible plans
   Because CMS allows the promotion of other enrollment opportunities during OEP, take advantage of the situation by promoting your dual-eligible/SNP plans. This type of advertising is likely to generate inquiries for your Medicare Advantage plan.
4. Incorporate brand advertising
   Incorporating brand advertising is a way to keep your plan relevant and top-of-mind during OEP. You cannot afford to go dark during this period.
5. Focus your advertising dollars where there is market disruption
   The best growth opportunities for OEP will likely be in those markets that experienced some type of disruption during AEP. Market disruption could include a competitor plan withdrawal or significant changes in a competitor’s plan benefits (such as an increase in monthly premium). These types of disruption will drive MA beneficiaries to shop for plans during OEP, as those who are affected will be feeling the impact of their recent AEP decision. For those MA beneficiaries who experienced a plan withdrawal, they will have a special enrollment period (SEP) to select a new plan. The special enrollment period will begin January 1 and end on February 28. Take full advantage of these opportunities.

As with any advertising initiative, please be sure to consult with your internal compliance team to ensure all advertising meets the Medicare Communications and Marketing Guidelines.