Nominal gifting! Everyone loves to receive free gifts, even if they may have promotional branding. If you want to get the attention of Medicare beneficiaries, sometimes a free gift, prize, or drawing may be the ticket. Just make sure your agency is following the CMS guidelines before you hand out nominal gifts.
What Is a Nominal Gift?
A nominal gift, per CMS rules, is a gift or experience with a small value. That value can be $15 or less per person or $75 for one person per year. If you are having a sales or marketing event and are offering a larger gift in a free drawing, that gift cannot be worth more than $15 times the number of people who are expected to attend the event.
Gifting without Discrimination or Obligation
Gifts cannot be contingent on enrollment, and must be given without discrimination. You can add a disclaimer when you promote the gift to make this clear. Add text such as: “Eligible for a free drawing, gift, or prizes with no obligation to enroll.”
What Nominal Gifts Can Be
Nominal gifts can be a raffle item, a concert ticket, or another large item, or it could be a smaller gift such as a $15 gift card to a local restaurant or movie theater.
What Nominal Gifts Cannot Be
Cash. Your nominal gift cannot be cash or a monetary rebate. That means you cannot give a cash prize or do a 50/50 raffle. It’s important to note that you cannot give a discount or cash incentive to clients for referrals or for enrolling in a plan through your agency.
Gift Cards to Big Box Stores. You cannot give away gift cards to big-box stores such as Walmart or Target. Those stores have so many offerings, the gift card is viewed as a cash value. If you want to hand out gift cards, you can choose smaller local businesses instead, while following the nominal gift value restrictions.
Meals in Marketing Contexts. You cannot provide or subsidize meals at sales or marketing events. Your agency can only provide light snacks and refreshments, but nothing that could be considered a meal. If you are at an educational event or an event in the realm of communications, you can provide a meal.
Offering nominal gifts with no obligation can be a good way to give your brand a positive association in the community. Follow the CMS guidelines to gift compliantly.
