📝 Submit Materials
Submit marketing and communication materials for compliance review before use. Reviews including marketing materials, this includes scripts, require the Spark Marketing Submission Spreadsheet completed and attached with each submission.
📄 Pre-Approved Spark Scripts
📋 CMS Compliance Requirement
As a Third-Party Marketing Organization (TPMO), you are subject to CMS oversight under 42 CFR § 422.2267 and § 423.2267. All marketing and communication materials must comply with federal regulations and CMS Medicare Communications and Marketing Guidelines (MCMG). Spark Advisors reviews all materials to ensure compliance before use.
Marketing vs. Communication: What's the difference?
Marketing vs. Communication: Quick Reference
Characteristic | Marketing | Communication |
Audience | Public / Multiple people | Individual consumer (1:1) |
Mentions Benefits/Plans | ✓ Yes | ✗ No |
Influences Enrollment | ✓ Yes | ✗ No |
Requires Spreadsheet | ✓ Yes | ✗ No |
Examples | Ads, websites, scripts, social media | Appointment reminders, follow-up emails |
📢 Marketing Materials
Public-facing promotion used to promote an agent, agency, product, plan, or event. Per CMS guidance, marketing includes any material intended to influence a beneficiary's enrollment decision.
Examples:
Print or digital ads
Social media posts
Websites or landing pages
Event materials
All scripts (phone, voicemail, presentations, talking points)
⚠️ Scripts Require Review Before Use
All scripts must be reviewed and reapproved before they are used. Good news! Spark maintains an approved script for your agency to use while yours is being reviewed an approved.
Required with each submission: All marketing materials must include the completed Spark Marketing Material Spreadsheet.
💬 Communication Materials
1:1 consumer messages sent directly to individuals, not for public distribution.
Examples:
Emails to individuals
Text messages
Appointment confirmations
Follow-up messages
Important: Communication materials cannot mention benefits, savings, plan types, or carriers. If they do, submit as Marketing instead. This distinction is defined in CMS Medicare Communications and Marketing Guidelines (MCMG).
Submission Checklist
Have these items ready before starting your submission to avoid delays:
Submitter Information: Your name, email, agency name, Agency NPN, and Lead Vendor Information (if applicable)
Material Description: Brief description of how, where, and when materials will be used
Material Type Selection: Identify whether materials are Marketing or Communication
For Marketing Material- read and follow the guidelines in the Marketing Material Requirements Guide below prior to submitting your marketing material for Spark Compliance Review.
For Communication Material- including a Lead Generation Form (BRC/PTC), read and follow the guidelines in the Communication Materials Requirements Guide below prior to submitting to Spark for compliance review.
Completed Spreadsheet (Marketing Only): Download, complete, and attach the Spark Marketing Material Spreadsheet
All Material Files: Upload all materials to be reviewed (PDFs, images, URLs, screenshots)
Provider or Co-Branding Disclosure: If your materials involve a healthcare provider, provider location, or third-party co-branding, you must disclose this in the submission form for appropriate review. CMS has specific requirements for marketing activities in healthcare settings per 42 CFR § 422.2274.
State Specific Guidelines
⚠️ California: If distributing materials in California, you must include your license number on all materials per California state insurance regulations. You'll confirm this in the submission form.
⚠️ Florida: Your company name cannot have the words “Medicare” in it. You may use it in other states, but you will be at risk of states changing their rules in the future to disallow “Medicare”. We recommend renaming your company and using DBAs (doing-business-as) where appropriate.
Frequently Asked Questions
Frequently Asked Questions
Do I need to submit materials before using them?
Do I need to submit materials before using them?
Yes. All marketing and communication materials must be submitted for compliance review prior to distribution or use. CMS requires TPMOs to ensure all materials comply with federal regulations before use (42 CFR § 422.2267).
How do I know if my material is Marketing or Communication?
How do I know if my material is Marketing or Communication?
Materials that promote an agent, agency, product, plan, or event—or could influence a beneficiary's plan decision—are considered Marketing. Materials that are direct, one-to-one messages sent to an individual consumer and not intended for public distribution may be considered Communication. If you are unsure, submit the material as Marketing.
Are scripts considered marketing materials?
Are scripts considered marketing materials?
Yes. All scripts, including phone scripts, voicemails, presentations, and talking points, are considered Marketing Materials per CMS guidance and must be submitted for approval before use. This includes any scripted content used in beneficiary interactions. Scripts must be reviewed and reapproved at least annually, even if the content has not changed.
When is the Spark Marketing Material Spreadsheet required?
When is the Spark Marketing Material Spreadsheet required?
The Spark Marketing Material Spreadsheet is required for all marketing material submissions, including scripts. All marketing materials must be listed in the spreadsheet with unique SMIDs (Standardized Marketing/Material Identifiers) as required by CMS for oversight and tracking purposes.
Do communication materials require the marketing spreadsheet?
Do communication materials require the marketing spreadsheet?
No. Communication materials do not require the marketing spreadsheet as long as they are informational only and do not reference benefits, savings, plan types, or carriers. If communication materials include plan- or benefit-related content, they must be submitted as Marketing and include the spreadsheet.
What happens if my submission is incomplete?
What happens if my submission is incomplete?
Incomplete submissions may be delayed or returned for revision. To avoid delays, ensure all required fields are completed, all materials are uploaded, and the marketing spreadsheet is included when required.
Can I submit drafts or concepts for review?
Can I submit drafts or concepts for review?
No. Only final versions of materials should be submitted for compliance review. Drafts or incomplete materials may be returned without review. You can email [email protected] for guidance or schedule time during our office hours to discuss any of your questions.
What if I change a previously approved material?
What if I change a previously approved material?
Any changes to approved materials require resubmission and approval prior to use. Additionally, all materials—including scripts—must be reviewed and reapproved at least annually, even if no changes have been made, to ensure ongoing compliance with current CMS requirements.
Do I need to resubmit materials annually even if nothing changed?
Do I need to resubmit materials annually even if nothing changed?
Yes. All marketing materials, especially scripts, must be reviewed and reapproved at least annually to ensure ongoing compliance with current CMS requirements. This applies even if the content has not changed. CMS regulations and guidance can change, so annual review ensures your materials remain compliant.
Need Help?
Need Help?
We're here to support you through the submission process. Schedule a meeting or contact us today.
Disclaimer: Not affiliated with the United States government or federal Medicare program. We do not offer every plan available in your area. Any information we provide is limited to those plans we do offer in your area. Please contact Medicare.gov or 1-800-MEDICARE to get information on all of your options.