The Centers for Medicare and Medicaid Services (CMS) at the Department of Health and Human Services (HHS) have been considering policy and policy and technical changes for 2024. Among those potential changes was a rule that would have prevented third-party marketing organizations (TPMOs) from partnering with one another. Thankfully, it appears that CMS has opted against instituting that rule and there is reason to believe that it is in part because of the efforts of REACH, a new leads industry trade group.
CMS had proposed a rule change that would have stated that “personal beneficiary data collected by a TPMO may not be distributed to other TPMOs.” REACH sent a public comment arguing that this rule would harm small businesses and consumers without doing anything to reduce the frequency of illegal robocalls. On April 5, CMS released its pre-publication version of the final rule and it thankfully does not include the TPMO provision.
REACH—whose name is an acronym for Responsible Enterprises Against Consumer Harassment—is a trade organization founded by Eric J. Troutman of TCPAWorld and Troutman & Amin.