Compliance Corner: Marketing/Sales Event – Reported as Private
As you know, agents are required to report all events to UnitedHealthcare.
Marketing/Sales Events must be categorized as formal or informal and may
be further classified as public or private.
What you may not know is Marketing/Sales Events must be open to the
general public regardless of the location. Events reported as private will only
prevent UnitedHealthcare telesales from collecting RSVPs from consumers to
that specific event. However, the private event is still open to the general
public and like all Marketing/Sales Events is subject to being secret shopped
by CMS and/or UnitedHealthcare.
Before scheduling a marketing/sales event at a venue that is not open to the
general public, discuss with the facility director and/or manager that any
consumer who wishes to attend the event must be allowed admittance. If
the facility cannot accommodate that requirement, you must select an
alternate venue.
Additionally, if you conduct private events in a closed facility (example:
nursing home, senior housing community, groups or associations, and
business offices) ensure that facility staff on duty at the time of the event
know to admit to the facility any consumer who wishes to attend.
Examples of events that are often reported as ‘private’ include but
are not limited to:
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An employer group retirement open house;
SilverSneakers™ or Fitness events;
Long term care facility residence events;
Senior center events;
Private clubs/groups (examples: Knights of Columbus or
American Legion)
Good to know:
 Any event may be secret shopped including formal/informal and
private/public;
 All marketing/sales events including employer group events and
events reported to the plan as ‘private’, are open to the general
public;
 Consumers must be allowed admission to any marketing/sales event;
 When selecting a venue, ensure that all consumers, not just those
belonging to the organization or residing at the facility will be allowed
July, 2011. Confidential and proprietary. For internal/agent use only. Do not distribute.
Compliance Corner: Marketing/Sales Event – Reported as Private
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admittance to the facility. If consumers not affiliated with the
organization or facility will be denied admittance, an alternate venue
must be selected
Events marked as ‘private’ will not be advertised by UnitedHealthcare
Marketing or promoted by UnitedHealthcare Telesales.
All events must be reported to UnitedHealthcare.
Contact information:
For Questions regarding Event Reporting/Changes/Cancellations, please
email: [email protected]
For Compliance questions regarding Marketing/Sales Events (formal and/or
informal) please email: [email protected]
Questions?
To ask a question regarding marketing, the Medicare marketing guidelines,
privacy issues, fraud and abuse issues, security questions or any question
related to ethics, please email them to [email protected].
Where to Report Violations
To report violations of illegal or unethical conduct, including violations of law,
contractual obligations and company policies (including the Principles of
Ethics & Integrity), privacy issues, or suspected fraud and abuse that
impact our company, employees should call 1-800-455-4521.
For non-employees please send any issues regarding illegal or unethical
conduct, including violations of law, contractual obligations and company
policies (including the Principles of Ethics & Integrity), privacy issues, or
suspected fraud and abuse that impacts UnitedHealthcare to
[email protected].
Note: All reports of the above activities are strictly confidential and subject
to the Company’s non–retaliation policy.
July, 2011. Confidential and proprietary. For internal/agent use only. Do not distribute.