Weekly Tip: Common Objections Series - Long-Term Care Advertising


Weekly Tips

Common Objections Series - Long-Term Care Advertising


Continuing our series on commonly issued objections, today's tip involves an objection frequently issued on long-term care advertising filings submitted under Standards for Individual Long-Term Care Insurance Advertising Material, IIPRC-LTC-I-3-ADV. It may be an understatement to say the Uniform Standards for long-term care advertising are more detailed than most state-specific advertising requirements. We find that there is a learning curve with the uniform standards for long-term care advertising filings, so reinforcing commonly overlooked aspects of these uniform standards may help filers address these areas and avoid objections.

Today's common objection is that the source to which any statistic or citation is attributed must include the date of publication. The standards provision is found in Section 2L as follows: "(1) The source of any statistics or citations used in advertising material shall be identified in the material, including its date of publication. Providing a web site address alone does not constitute credible sourcing." This provision of the uniform standards applies to all types of advertising material defined in the standards (institutional advertising material, invitation to inquire and invitation to contract). The date of publication objection arises most frequently with attributions to web sites. A citation to a general web site address, such as www.longtermcare.gov, cannot generally be attributed to a single date of publication. The most reliable way to satisfy the standard is to use a statistic from a discrete publication, for example the publication "Medicare and You, Centers for Medicare and Medicaid Services, 2014." A link to the publication may be included if it is available online.

Compliance with the standard will vary based on the source and type of statistic being cited, but including the date of publication is necessary to comply with the uniform standards. Ensuring that your long-term care advertising filing contains a date of publication and complete citation for each source included in the advertising material will reduce the number of objections during your filing's review. Using the checklists for the applicable Uniform Standard(s) found on the Record along with the Best Practices Checklist found on the Company Resources web page will help remind you of the required information each time.

If you have any questions about IIPRC submission requirements, please contact the IIPRC Office.