Plan-initiated provider activities are those activities conducted by a provider at the request of an MA organization. During a plan-initiated provider activity, the provider is acting on behalf of the MA organization. For the purpose of plan-initiated activities, the MA organization is responsible for compliance with all applicable regulatory requirements.
During plan-initiated provider activities, MA organizations must ensure that the provider does not:
- Accept or collect scope of appointment forms
- Accept Medicare enrollment applications
- Make phone calls or direct, urge, or attempt to persuade their patients to enroll in a specific plan based on financial or any other interests of the provider
- Mail marketing materials on behalf of the MA organization
- Offer inducements to persuade patients to enroll in a particular MA plan or organization
- Conduct health screenings as a marketing activity
- Distribute marketing materials or enrollment forms in areas where care is being delivered
- Offer anything of value to induce enrollees to select the provider
- Accept compensation from the MA organization for any marketing or enrollment activities performed on behalf of the MA organization
During plan-initiated provider activities, the provider may do any of the following:
- Make available, distribute, and display communication materials, including in areas where care is being delivered
- Provide or make available marketing materials or enrollment forms in common areas