Marketing Activities and Compliance

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

• Providers may not be fully aware of all First Choice VIP Care Plus (Medicare-Medicaid Plan) 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 his/her needs and potential options to meet those needs, they may do so. Providers may engage in discussions with a member should he/she seek advice.

• Acceptable and Unacceptable Marketing Practices
• Provider Affiliation Information