Relating to allowing Medicaid managed care organizations to engage in marketing about the availability of certain private health benefit plan coverage.

Contracts

• Uniform Managed Care Contract (UMCC): Expect a unilateral amendment from HHSC incorporating these new marketing permissions and restrictions.
• Vendor Master Services Agreements (MSAs): You must amend agreements with third-party marketing agencies and call centers. Insert strict indemnification clauses regarding the ban on "material or financial gain" incentives. If a vendor offers a prohibited gift card, your MCO will be liable for the sanction.

Hiring/Training

• Call Center Scripting: Scripts must be rewritten to include a mandatory "Cost-Sharing Disclosure." Agents cannot simply highlight coverage; they are legally required to inform the recipient about deductibles and copayments associated with the private plan.
• Field Marketing: Field teams must be retrained on the prohibition of incentives. "Value-added services" must be distinct from enrollment incentives to avoid violating the new ban on material gain.

Reporting & Record-Keeping

• CRM Updates: Your Customer Relationship Management systems must be configured to log that the mandatory cost-sharing disclosure was delivered. In the event of an audit or a Deceptive Trade Practices claim, you must be able to produce a timestamped record verifying the consumer was warned about costs.
• Material Approval: All new cross-selling brochures and digital assets must be submitted to HHSC for approval prior to use.

Fees & Costs

• No New State Fees: There are no new licensure fees.
• Operational Costs: Budget for legal review of marketing materials and IT costs to update CRM workflows for disclosure verification.