A tweet from biotech/pharma industry watcher Sarah Vogel points us to an interesting document from the Centers for Medicare and Medicaid Services (CMS) outlining "draft guidance on allowable usage of social networking sites" by Medicare Advantage providers and other private sector entities that deliver Medicare benefits -- known collectively as "plan sponsors."
I was amused by this section:
The public interactive features of social networking sites must be disabled. For example, interactive features such as chat, messaging, blogging, or wall discussions will not be permitted, given that these features encourage ongoing interaction with beneficiaries which, by their nature, are not reviewed by the plan sponsor in advance and could not receive CMS prior approval.
Furthermore, "plan sponsors cannot use social networking sites as a means to initiate unsolicited contact."
If you subtract "chat, messaging, blogging and wall discussions" from a social networking site, and prevent employing the features of the site to approach other users, what exactly do you have left? A static Web page? What is the point behind creating guidelines for use of social networking sites that forbid any social networking?
But looking a little closer, we see that the one of the reasons cited for the guidelines is "to ensure that plan sponsors are not using these social networking sites in ways that... violate the Medicare Marketing Guidelines."
And that seems to be the key. As Dawn Teo reported last September in the Huffington Post private Medicare providers have been notorious scare-mongers on the topic of health care reform. Some have sent mass mailings to their plan beneficiaries warning them off all sorts of horrible things that might happen after reform -- benefits cut, drugs no longer subsidized, et cetera. The Centers for Medicare and Medicaid Services does not look fondly on such behavior.
Teo:
According to a source with inside knowledge of the way CMS regulates marketing guidelines, Medicare providers are only allowed to communicate with plan members about the benefits they have now, not about possible changes to benefits. They are also not allowed to use plan-related communications to lobby for policies or legislation.
So the draconian guidelines on social networking seem at least partially designed to prevent Medicare Advantage providers from using those networks to do what they do best: spread viral messages intended to rally support for an agenda. We'll see how well that works.
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