Can I provide food or small gifts at an event? What about a raffle or a thank-you gift for referrals?
Yes, both are addressed by CMS rules, but with limits. Meals are prohibited at marketing/sales events but may be allowed at educational events, and gifts must stay within the "nominal value" cap. Referral payments are also capped by dollar amount, not treated as gifts.
What the rule says
On food:
“MA organizations may not do any of the following:”
“Provide meals to potential enrollees regardless of value.”
However, guidance clarifies:
“Meals may be provided at educational events that meet CMS's regulations and other events that would fall under the definition of communications.”
“Refreshments and light snacks are not considered "meals." Plans should ensure that items provided could not be reasonably considered a meal and/or that multiple items are not being "bundled" and provided as if a meal.”
On gifts:
“Offer gifts to beneficiaries, unless the gifts are of nominal value (as governed by guidance published by the HHS OIG), are offered to similarly situated beneficiaries without regard to whether or not the beneficiary enrolls, and are not in the form of cash or other monetary rebates.”
“HHS OIG's current interpretation of "nominal value" is set forth in "Office of Inspector General's (OIG's) Policy Statement Regarding Gifts of Nominal Value To Medicare and Medicaid Beneficiaries," and is no more than $15 per item or $75 in the aggregate, per person, per year.”
On referral payments (a different category from gifts):
“Payments may be made to individuals for the referral (including a recommendation, provision, or other means of referring beneficiaries) to an agent, broker or other entity for potential enrollment into a plan.”
“The payment may not exceed $100 for a referral into an MA or MA-PD plan and $25 for a referral into a PDP plan.”
The excerpts do not specifically address raffles, so I cannot confirm how that particular format would be treated under the gift or cash-equivalent rules.
Carrier and FMO rules are often stricter than CMS rules. This tool reports what CMS sources say and is not legal advice. Enrollment guidance shown is the CY 2027 version. Regulation text reflects the CY 2027 marketing rules, which apply to marketing beginning October 1, 2026.
This answer was generated by mapdbot from the sources listed below on September 23, 2026 and checked against them. Regulation text: eCFR as of 09/15/2026. It is for licensed insurance agents, is not legal advice, and does not cover carrier or FMO rules.
Sources cited
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