Top 5 Considerations for Choosing a CMS Marketing Surveillance Company

For the past eight years, the Center for Medicare & Medicaid Services (CMS) has conducted secret shops to ensure that marketing representatives, agents, and brokers comply with CMS marketing requirements and guidelines.

Although CMS develops their own undercover secret shop programs, they strongly recommend and encourage Plan Sponsors to execute their own marketing surveillance secret shops in order to:

• Ensure agents, brokers, and plan sponsors adhere to CMS marketing requirements and market their health plan products appropriately;
• Identify areas of non-compliance and take corrective action to address deficiencies;
• Analyze trends across MAOs, MA-PDs, and PDPs with respect to marketing practices; and,
• Ensure agents, brokers, and plan sponsors are adhering to CMS marketing requirements.

As a top provider of secret shopping programs that mirror CMS’s secret shop audit questionnaires since 2009, TrendSource suggests the below top 5 considerations for choosing a secret shop marketing surveillance company:

Consideration #1: Compliance Requirements

• Secret shop providers should have the following compliance procedures in place:
  1. Ensure all employees and Independent Contractors (ICs) receive Fraud, Waste and Abuse certification prior to completing any Medicare based assignments
  2. Complete monthly OIG/SAM (and other) exclusion list database checks for employees and ICs
  3. Key personnel training based on AHIP certification standards

Consideration #2: Flexibility

• Providers for secret shop marketing surveillance programs should have the ability to develop and execute all phases of compliance programs in-house. Since CMS updates their questionnaires, scenarios, scoring, and language requirements on an ongoing and annual basis, the right partner is a provider who can make any necessary changes on the fly to ensure the program mirrors the current CMS surveillance tools.

Consideration #3: Proven Methodology

• Having an experienced provider is critical to the success of the program. Look for a provider that has developed recruitment, instructional, communication, and maintenance processes that support the complex needs of these marketing surveillance programs. This will ensure that secret shoppers understand the scope of their work for each program clearly and yield the highest quality results.

Consideration #4: Reporting

• Provider reporting platforms should be designed and developed to allow flexibility for customization to meet the specific needs of the organization. At a minimum, reporting should include dashboard reports, audit detail results, agent/broker breakdowns, and summary and trending reports.

Consideration #5: Implementation

• In order to see high-quality results, the right partner should provide support in identifying the key success factors and common challenges with integrating a marketing surveillance secret shop program. A premier provider will not only be able to understand, document, and roll-out the program, but will also provide insights, recommendations and best practice techniques based on their experience developing and executing these programs.

In order to adhere to marketing surveillance guidelines, take the above considerations into account while you are selecting a provider for your secret shop compliance program. Best of luck!

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