Q. What is the rule for providing food and refreshments at Medicare events?
A. It is that time of year again, and we are preparing for our Medicare events. It is imperative to keep in mind the rules for providing food and refreshments at Medicare events. The Medicare Marketing Guidelines provide guidance on the do’s and dont’s of providing food and drinks at Medicare events.
Before you call a caterer, you will want to ensure you are adhering to the Medicare Marketing Guidelines (MMG) for providing food and refreshments at Medicare events. You do not have to flip through the entire document to find the guidance of hosting a compliant educational, or marketing and sales Medicare Event.
Here’s what you need to know:
You can provide food at your Medicare Marketing and Sales Event, however, you are only allowed to provide “refreshments and light snacks.” You are not allowed to provide (or pay for) meals. You will have to use your best judgment on the food you provide. It is your responsibility to ensure everything provided cannot be considered a meal. You will also have to be mindful that refreshments and snacks cannot be grouped together or eaten as if they were a meal.
As far as educational events go, there is an exception to the rules mentioned above. You can provide food and snacks at educational events, but you are also allowed to provide meals. If you would like to provide meals at educational events, however, there are additional rules that must be followed:
- The event must meet Centers for Medicare and Medicaid Services’ (CMS) strict definition of an educational event. When meeting CMS’s definition, the event must be designed to inform beneficiaries about Medicare Advantage, Medicare Part D Prescription Drug Coverage, or another Medicare program. The event absolutely cannot include any marketing efforts. (e.g., you cannot advise, or try to advise, any potential beneficiary towards a particular plan or a set number of plans. You can only educate the attending beneficiaries about all of their product options.)
- Any meals provided must comply with the nominal gift required listed in MMG section 70.1.1, meaning that any meal provided (whether to a group or an individual) cannot exceed a nominal value per person. (e.g., if you scheduled an event with 20 attendees, and you are planning to provide meals for each person and spend $300 on the meals in total; the value of each meal, per anticipated attendee, is a nominal $15.
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Sources: CMS.gov/Medicare/Health-Plans/ManagedCareMarketing/Downloads/2017MedicareMarketingGuidelines2.pd
