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I found this one a bit interesting:
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70.4.1 – Educational and Marketing Events
42 CFR 422.2268, 423.2268, 422.504(f)(2), 423.505(f)(2)
Plans/Part D Sponsors are not required to upload educational, formal and/or
informal marketing/sales events in HPMS. Plans/Part D Sponsors must keep
accurate records of all marketing/sales and educational events, and CMS
reserves the right to request event information at any time.
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I suppose the reporting requirements proffered by plan sponsors will still be on the "strict" side.
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70.4.1 – Educational and Marketing Events
42 CFR 422.2268, 423.2268, 422.504(f)(2), 423.505(f)(2)
Plans/Part D Sponsors are not required to upload educational, formal and/or
informal marketing/sales events in HPMS. Plans/Part D Sponsors must keep
accurate records of all marketing/sales and educational events, and CMS
reserves the right to request event information at any time.
*********************
I suppose the reporting requirements proffered by plan sponsors will still be on the "strict" side.