Medicare Marketing & Enrollment 2010 Compliance and Marketing

1. Aligning the Odd Couple – Marketing and Compliance Medicare Marketing and Enrollment Strategies 2010

5. Market landscape is changing Entrance of M&N Supplements New Supplement Plans Reduced MA reimbursements The fall of PFFS Expansion of HMO and PPO Recession fallout Group market opportunities Booming market Source: “A New Deal? What’s New for Medicare”?; Dawn McFerrin, Supplement to Sales Agent Journal , October 2009

6. Surveillance was formerly moderate

8. Accountability by CMS intensifies Scope of Horizontal Secret Shopping of Marketing Events During AEP Total number of horizontal secret shops conducted 811 Number of MA organization shops 762 Number of PDP organization shops 49 Number of shops allocated to high-risk organizations 409 Number of shops allocated to all other organizations 402 Minimum number of shops conducted for any shopped organizations 1 Maximum number of shops conducted for any individual organization 134 Overall Industry Performance for Horizontal and Vertical Events Total secret shops conducted 1,463 Percentage of organizations with violations 51.6% Percentage of secret shopping events with violations 52.2% Organizations issued notices for secret shopping violations 28 Source: Contract Year 2009 Marketing Surveillance Summary Report, CMS

10. Snapshot poll of key MAO functions Source: Marketing and Compliance Poll, March 2010, n=40

11. Most plans under 50,000 MAPD members Source: Marketing and Compliance Poll, March 2010, n=40

12. All plans are under tight scrutiny Source: Marketing and Compliance Poll, March 2010, n=40

13. Most believe there is collaboration Source: Marketing and Compliance Poll, March 2010, n=40

14. Most see knowledge up and cases down Source: Marketing and Compliance Poll, March 2010, n=40

15. Regulatory halo effect Source: Marketing and Compliance Poll, March 2010, n=40

16. But not all levels agree on regulatory status Source: Marketing and Compliance Poll, March 2010, n=40

17. Lack of clarity leads to risk Source: Marketing and Compliance Poll, March 2010, n=40 Lack of Clarity Decisive Actions Audit risk remains prominent

18. Big disconnect on status of compliance

19. It could be as simple as motivations Compliance Marketing Sales Heartburn Heartburn 2 Heartburn Frustration Volatility Source: David McClelland (adapted), staff surveys Sales = Personal Power Marketing = Social Power Compliance = Expert Power Achievement Affiliation Power

22. Structure affects confidence in compliant behavior

24. Working together is a great theory Source: Marketing and Compliance Poll, March 2010, n=40

25. Gaps still remain between the two departments Source: Marketing and Compliance Poll, March 2010, n=40 Oversight Knowledge Leadership