All marketing communications, advertising and materials produced and/or distributed on behalf of Humana or any of its insurance affiliates to customers or potential customers must adhere to applicable guidelines and practices, which include but are not limited to the following:
- NAIC Advertisements of Accident and Sickness Insurance Model Regulation
- NAIC Advertisement of Life Insurance and Annuities Model Regulation
- NAIC Model Rules Governing Advertisements of Medicare Supplement Insurance with Interpretive Guidelines, and applicable state laws and regulations
- State Departments of Insurance requirements
- State-enacted regulations and rulings, as coordinated and implemented via Humana’s regulatory implementation process
- CMS Medicare Communications and Marketing Guidelines and relevant CMS laws, regulations, and guidelines (e.g. 42 CFR 422 and 423, Chapters 3 and 4 of the Medicare managed Care Manual and/or the Prescription Drug Benefit Manual, relevant portions of the annual CMS Call Letter, other directives issued by CMS)
- CMS/State Medicare-Medicaid Marketing guidelines, as issued, in the states where Humana offers Medicare Medicaid Plans
- Applicable law, guidelines and/or contractual provisions related to any Medicaid programs in which Humana participates
- Not employ marketing practices or benefit designs that will have the effect of discouraging the enrollment of individuals with significant health needs in QHPs as defined by Title 45 of the Code of Federal Regulations Section 156.225(a) and (b) as it relates to the Patient Protection and Affordable Care Act; Exchange and Insurance Market Standards for 2015 and beyond
- Relevant requirements or recommendations resulting from regulatory filing activities and feedback from regulatory bodies
- Results from regulatory audits
Areas responsible for marketing support or communications are aware of the guidelines for the respective business lines and products about which they communicate. These areas operate in a manner and develop processes that ensure ongoing adherence to the relevant laws, regulations, and guidelines and consistent application of agreed-upon required language, formats, disclosures, etc.
Areas responsible for marketing support or communications consult with Regulatory Compliance, and Legal, as needed, in carrying out marketing, advertising, and communication activities.
Medicare and Group Commercial Products are sold primarily through agents and consultants. Consultants are primarily used to make product recommendations to Humana customers. Humana also uses Managing General Agents (MGAs) to market products.
Humana creates compelling brand, positional and product advertisements to consumers and group business audiences by way of TV, radio, print, digital, collaterals, direct-response and sponsorship channels. At an enterprise level, all marketing, consumer and member communications systems fall under Humana’s Chief Marketing Officer.