CMS has broadened the definition of “marketing” to include materials that mention any type of plan benefits. This requirement applies to all new materials, as well as existing materials that were previously reviewed. In it’s May 10, 2023 memo, CMS stated that “any material of activity that is distributed via any means (e.g., mailing, television, social media, etc.) that mentions any benefit will be considered marketing and must be submitted to the Health Plan Management System (HPMS). See more details with CMS's Definition of Marketing 5-10-23

Effective July 10^th, TPMO’s, including agents and brokers, must do the following:

1. Determine if their communications meet the new definition of marketing and then submit materials for marketing review
2. Ensure that all multi-plan materials that include “intent” and mention any benefits are provided to the respective carrier and then submitted to HPMS.