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Marketing Activities and Compliance

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

  • Providers may not be fully aware of all Keystone First VIP Choice (HMO SNP) 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.

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