Preparing For Your CMS Marketing Surveillance Program – A Checklist

It’s officially summer, and we all know what that means! No, not sunshine, 4^th of July BBQs …those in the Medicare world know that summer means the Medicare Annual Enrollment Period (AEP) is fast approaching.

Some of you may already have your secret shop marketing compliance plans in place for the upcoming selling season, and others may just be dipping the proverbial toe in the water of secret shopping.

In order to give you a head start as you begin to execute your plans for this year, we have detailed five steps to prepare for a successful secret shop marketing surveillance program.

1. Understand your needs

CMS understands (as do we) that your needs and areas of risk are unique. The first step in implementing a successful program is to understand your specific needs. This allows you to focus your efforts on what really matters for YOUR organization. Your vendor will be able to help guide you and recommend a specific approach, but you should have a general understanding of your overall hot buttons.

Things to consider:

• How large is your sales force?
• Does it consist primarily of Internal or External (Brokers) Sales Agents?
• What are your specific areas of risk?
  • What is CMS measuring?
  • Where are your complaints highest?
  • Do you have specific agents or FMOs you want to ensure are shopped?

2. Choose the correct vendor

Once you understand your needs, you’ll need to go about finding a vendor that has the capabilities to service those needs. For example, if shopping 1:1 appointments or TTY/Interpreter Services has been identified as a high priority for you, you’ll want to make sure your vendor has the capabilities to successfully execute those programs.

Particularly, make sure you address the following:

• Does the vendor understand your market, and are they able to help guide you towards a strong compliance program?
• Are they invested in continuous education and improvement?
• Are they flexible enough to address changes you may have throughout the contract year?

For further tips on how to choose the correct vendor, see our article on this very topic.
3. Make sure the right people are on board

In order to ensure that your program runs smoothly, you’ll want to make sure that key stakeholders are aware of and on board with the program. Ideally, it’s best to have collaboration between the Sales, Marketing and Compliance teams. Between these different groups, you’re including individuals who have access to all of the information that you’re going to need to make the next step much easier.

4. Gather the necessary information

This one is paramount. Without receiving correct and timely information, your vendor will be unable to launch a successful program for you. A little pre-planning to ensure there are processes in place for the following items will allow you to get the most bang for your buck from your secret shop compliance program.

1:1 Appointments

• Make sure you understand the lead method for your Internal agents as well as your Brokers. Your vendor should try to align their shopping process to mirror how normal leads come in, to ensure that secret shops are as “secret” as possible.
• It’s really important to obtain accurate information regarding where your agents actually sell and market your plans. Additionally, you may need to provide your vendor with accurate phone numbers for contacting your agents (depending on the lead method you define). Whatever work can be done up front to verify the accuracy of this information will go a long way in providing you with the program results you are looking for.

Marketing Events

• Typically your vendors will be able to work off the event schedule you upload to HPMS. The sooner you can get this list to your vendor, the better. Having a process in place to get your agents to submit events by a certain date will make the likelihood of early-in-the-month events being shopped more of a possibility.
• Similarly, have a process in place to be sure any event cancellations or modifications are sent to your vendor ASAP, so they can modify their shopping plans as needed.

Call Center Monitoring

• Depending on how large your plan and call center is, this task can vary in scale. Below are the highlights of what you’ll need:
  • Different phone lines/numbers
  • What plans and product lines are offered through each phone line, and what the service areas are for those plans
  • Days/Hours of operation of call centers
  • Basic understanding of your IVR process, call center scripts, and call overflow procedures

5. Be prepared to pilot the program

With the above four steps completed, you will be well on your way to launching a successful program. However, you should still be prepared to make minor tweaks and adjustments to your program after it launches. Things like lead types and questionnaires may seem perfect in theory, but typically the need for slight modifications will arise. Your vendor should be able to make accommodations for these changes in order to maximize program success through AEP and during the lock-in period.

Once your program is implemented, things don’t necessarily stop there! Visit our previous blog post to see 5 Keys to Running a Successful Secret Shop Compliance Program.