Final Benefit Submission Is Done. Top 5 Items To Focus on Now!
Benefits were submitted on June 5, 2017. Too many times we see health plans wait until the last minute to complete important information. This tends to lead to incorrect mailings and advertising getting into the marketplace with costly errata mailings occurring. Gorman Health Group recommends you start with a strong work plan in place to get the following documents completed, starting now:
Annual Notice of Changes (ANOC) and Explanation of Coverage (EOC). The 2018 model materials have been released by the Centers for Medicare & Medicaid Services (CMS). The ANOCs and EOCs are typically the most difficult documents to develop, get reviewed, and have printed. It is best to develop these documents now since they must be mailed by September 30, 2017. Also, make sure you have a reputable printer who understands these documents and the importance of meeting CMS deadlines.
Summary of Benefits (SBs). As stated during the CMS Spring Conference, CMS will no longer be issuing annual memos for the SB; instead, changes will be listed each year in the Medicare Marketing Guidelines (MMG). Although the 2018 MMG have not yet been released, CMS did highlight the following changes for 2018:
- No more hard copy changes.
- Outpatient hospital coverage will be listed right after inpatient hospital coverage.
- The extra premium for optional supplemental benefits can be included in the SB.
- The document must be labeled “Summary of Benefits,” and the plan year should be visible on the cover.
- If a benefit is not covered, such as transportation, you still need to list the benefit and state “Not covered.”
- Plans can add other benefits not listed by CMS to the SB and should label the section “Additional Benefits.”
It is important to start development of the SB early since it is typically inserted into sales kits/packages and needs to be in the hands of your sales representatives no later than October 1. Printing, fulfillment, and shipping of the SB is a timely and costly endeavor.
Sales Kits/Packages. In addition to the SB, you should begin working on the following materials:
- Enrollment Form. If you are still working with enrollment forms, start now. Although the Medicare Managed Care Manual Chapter 2, Medicare Advantage Enrollment and Disenrollment, guidance is not usually updated until August, it is important to have this document submitted and ready to go if you have to make changes if it is non-model, especially since this is part of the sales kit/packages.
- Benefit Highlights Sheet. Although CMS states they will continue to allow benefit highlights to be developed, they prefer the prospect reads the SB instead. GHG understands that benefit highlights sheets are a great resource for sales staff, as well as for prospective enrollees who wish to quickly view key benefits most important to them.
Sales Presentations. If you develop sales presentations for your sales team, start working on them now. The last thing you need is to have your sales force sitting with a prospect and not have the approved resources.
Annual Election Period (AEP) Mailing #1. There is nothing worse than the phones not ringing, idle sales reps, and websites with no traffic. We have seen this firsthand, and it is not pretty. Get your mailings started! Even though you may think it’s too early, it isn’t. There are so many interruptions during the summer months with employee vacations, release of the MMG, and review periods, it’s best to start as soon as possible.
One last important NOTE: As you know, filed benefits are not final until they have been “blessed” by CMS. Every year, we hear complaints about how benefit changes are communicated – or not communicated. Please make sure you have a communication strategy in place to update all departments’ if/when benefits change. This process – when done correctly – saves money, time, and embarrassing communications with CMS!
Our team of experts can develop or review your sales collateral and creative by product type to help ensure your high-impact messaging is both targeted and compliant. Contact me directly at dhollie@ghgadvisors.com for more information.
Resources:
Want to stay up to date on policy and regulation changes? The Insider is GHG’s exclusive intelligence briefing, providing in-depth analysis and expert summaries of the most critical legislative and political activities impacting and shaping your organization. Read our full press release >>
New Webinar! Join us on Tuesday, June 20, from 1-2 pm ET, for a webinar on best practices for agent onboarding and oversight, compliant and efficient solutions to onboard and certify agents for the 2018 selling season and more! Register now >>
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Top Challenges in Provider Data Management
While health plan provider directory inaccuracies have been at the forefront of the news, regulatory agencies, and consumer protection agencies, the directories are only the tip of the iceberg in how difficult provider data management is for health plans. Plans continue to gather information on providers in a multitude of ways and from a variety of functional areas, continue to create conflicting repositories of provider data, and thus continue to face the painstaking and almost always manual validation of provider information.
As we have worked with clients through Medicare Advantage service area expansion applications, exception process, and the upcoming bid filing, we have repeatedly seen plans faced with spending hours having their provider teams manually tracking down providers and correcting provider information in order to prepare accurate Health Services Delivery (HSD) tables and exception request forms. A few of the top challenges found have been the following:
- The CMS Provider Supply File: Centers for Medicare & Medicaid Services (CMS) offered an olive branch in providing the list of servicing providers they use as a source when reviewing a plan’s provider network. Plans, however, had a difficult time validating the provider information they had internally against the Provider Supply File and using it to their advantage in preparing network exceptions.
- Inter-plan relationships and provider sharing between lines of business oftentimes had unclear boundaries on which providers could be used or were contracted for the various products at hand.
- When reviewing an overall coverage area, they appeared complete; when broken out into potential provider-sponsored plan (PSP) offerings, provider gaps were found.
With all three of these situations, plans were affected by a lack of time to mitigate the compliance risk facing their networks. As health plans move forward in finding ways to keep their directories in compliance, we challenge you to take a step back and look at provider data management in a holistic manner to solving directory, credentialing, and network adequacy issues, improving care management with better data management on what your network partners offer, improving relationships with your Star Ratings and risk adjustment vendors, and ensuring a strong network management program. With a spotlight on network management across all government-sponsored programs, let Gorman Health Group be your partner in designing a provider data management system that will meet your needs.
Resources:
GHG’s multidisciplinary team of experts will assess the alignment of your products, your current network and your market to translate your business strategies into practical, efficient and rigorous work processes with the highest degree of compliance and accountability. Visit our website to learn more >>
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Marketing Takeaways from CMS’ Spring Conference
Although the Centers for Medicare & Medicaid Services (CMS) Spring Conference is typically thought of as a “compliance” conference, there is always important information that comes from the conference which affects Marketing. It is important to understand the information coming today instead of waiting for a CMS memo or the Medicare Marketing Guidelines (MMG). It is also a great way to hear how CMS personnel are thinking about a subject instead of just trying to infer their thoughts from the MMG. The following are some takeaways that may affect you and your plan.
Summary of Benefits (SB)
CMS reviewed 191 SBs – one from each parent company. If you haven’t heard from CMS about your SB, congratulations, CMS did not find any issues with your document. CMS gathered the SBs from each plan’s website, so make sure your documents are uploaded timely and the correct document is utilized. Here are some of our notes from the conference on SBs.
- CMS stated one of the biggest concerns they saw was plans not using the correct order of benefits. Plans are required to maintain the specified order. Monthly premium, deductible, and maximum out-of-pocket (MOOP) should be first, followed by drug benefits. Some plans were alphabetizing benefits, including other benefits, and this is not allowed. In addition, make sure you are using the correct version of the SB. CMS noticed some SBs had multiple fonts in one sentence, brackets were not removed, and track changes were in SBs. Furthermore, some plans had incorrect cost-sharing in their SBs.
- New for 2018:
- No more hard copy changes.
- No annual memo will come out this year; 2017 requirements will continue for 2018 – a copy of the memo and any 2018 changes will be listed in the 2018 MMG.
- Outpatient hospital coverage will be listed right after inpatient hospital coverage.
- Extra premium for optional supplemental benefits can be included in the SB.
- The document must be labeled “Summary of Benefits,” and the plan year should be visible on the cover.
- If a benefit is not covered, such as transportation, you still need to list the benefit and state “Not covered.”
- Plans can add other benefits not listed by CMS to the SB and should label the section “Additional Benefits.”
- Although CMS will continue to allow plans to utilize “benefit highlights,” “Benefits at a Glance,” and other types of marketing documents to highlight their benefits, CMS would prefer plans not utilize these documents and have prospects and members read the SB instead.
Supporting Access to Information for Individuals with Disabilities
CMS explained plans should be very familiar with Sections 508 and 504 of the Rehabilitation Act. Section 508 explains the media/electronic needs, and Section 504 explains accessibility, regardless of technology utilized. CMS stated access extends beyond hearing and visual impairments. Plans need to understand what the requests are for their disabled members and meet those needs in a timely manner – as though it was a member without a disability. This requirement must also be provided by your downstream contractors, so if you utilize a call center or other vendors that handle and fulfill prospect or member requests, make sure you have policies and procedures to handle these types of requests.
“The agency expectation is that individuals with disabilities are provided equal opportunity to participate in your program, and you should want that, too,” says Regan Pennypacker, Senior Vice President of Compliance Solutions. “We know this is operationally tricky, but this is an opportunity for innovation. A plan must work with beneficiaries to identify how they would like to receive information and make sure the info is provided in a timely manner.” CMS stated they are very interested in working with plans and hearing about their challenges and also best practices and successes.
Provider Directories Review Update
Provider directories will continue to be a challenge for everyone, and although CMS acknowledges this is a difficult endeavor, plans are responsible for their data. CMS also stated, since the provider is contracted by the plan, it is the plan’s responsibility to make sure they get the proper information from the provider. Although we could spend a lot of time discussing what CMS said about directories, we have provided a few things you want to be aware of from a marketing standpoint:
- Make sure what is on your website is the latest and most up to date! Understand how and when it gets updated.
- These are common errors CMS wants addressed in provider directories (both paper and online):
- Plans must include notation if provider is accepting new patients or not. Make sure meaning of notation is clear.
- Do not assume specialists are accepting new patients.
- If listing provider prior to effective date, include effective date in directory.
- Identify when provider has significant limitation to the patients they see (e.g., only treats members of a Native American tribe).
- Does provider practice all their specialties at all locations?
- List facilities as facilities and providers as providers. For example, they sometimes see surgeons listed with facility address where surgeries are conducted, but it should be address of where the member can get an appointment.
- The languages spoken at doctor offices.
This discussion will continue to be a hot topic for CMS. As a marketer, we need to understand the data we are getting to develop these documents and help ensure it is meeting the guidelines set forth by CMS.
These are just the highlights from a few of the topics. Reach out to your Compliance Department to understand what might affect you going forward!
Resources:
CMS also recently held its 2017 Audit and Enforcement Conference. Our Senior Vice President of Compliance Solutions, Regan Pennypacker, provides a recap here >>
Stay connected to industry news and gain perspective on how to navigate the latest issues through GHG’s weekly newsletter. Subscribe >>
Checklist for Developing Your Marketing Plan for 2018
Developing a new marketing plan each year is a “clean slate” opportunity to look at your marketplace and develop strategies to meet your goals. Gorman Health Group has seen how baby boomers are beginning to change the landscape of Medicare marketing, and it is important not to be left behind. We have developed a checklist to help ensure your marketing plan for 2018 is very inclusive!
It is important to make sure your strategies fit your market to get the maximum result. If you are struggling with your sales, marketing and strategy plan, give us a call. Gorman Health Group is fortunate to be able to work with health plans across the country and understands how to dissect the marketplace to understand your best potential for success. Call us today!
Resources:
Three Important Tips to Make Sure Your Bid Process Is Successful This Year
Now that applications are completed, it’s time to get started on developing bids for 2018. In our experience working with many health plans, we have seen a wide range of strategies for developing bids over the years. Some of the strategies have worked very well, but many times we are working to improve or develop a more robust system because something went wrong the year before. Whatever your scenario might be, here are three important tips to help your bid process run smoother this year:
1. This Is Not a One-Person Job – Gorman Health Group (GHG) believes the bid process needs to be a team approach, with one clear leader, and include representatives from the following areas to ensure the best product is brought to market, and, when it is offered, the implementation of the product is seamlessly implemented. Some of the members who should be included are the following:
• Vice President, Medicare
• Product/Sales/Marketing Representatives
• Finance/Actuary/Healthcare Economics
• Network
• Pharmacy
• Medical and Health Management
• Compliance
• Operations
It is important this team succeeds as a group. Everybody needs to be accountable for his or her part in the process. Several times we have seen the process fall apart when team members didn’t show up for meetings and waited until the last minute to complete their assignment which was critical to completing the bid. Accountability is key! And that is why we recommend a senior management executive be a part of the process. There is nothing worse than making changes the day before the bid is due!
2. Have a Plan in Place – Having a bid document in place to level-set the team of the goals of the bid development process is critical to getting everyone on the same page upfront. When you have such a disparate group of departments working together with different goals, it is important to level-set in the beginning. Some items that should be included are the following:
• Understanding of the current financials profitability and what the return on investment should be in the next year
• Enrollment goals and forecasts
• Product goals and target market
• Competitive product and premium analysis
• Market, Annual Election Period, and member analysis
• Network analysis
• Formulary overview
• Medical Management programs and their effectiveness
This type of document, where each member provides guidance to the process from the outset, helps to form a project plan and clear objectives.
3. Strong Communication Process – GHG has never participated in a bid process where there is only one iteration of benefits. There are typically many iterations and changes along the way. In addition, if new benefits are added, there may be the need for new vendors and contracts to be developed. Changes to benefits or new benefits can cause real implications to claim systems and other operations. There are also very critical mandated marketing and advertising materials being developed that must be 100% accurate. We have seen issues occur in each of these areas because of a lack of a strong communication process. There must be a consistent methodology to provide individuals responsible for implementing benefits the opportunity to get it done right. There is no one way to do this. Your job is to make sure it is done the right way.
Having a strong bid process is an important step in making sure health plans are developing the most meaningful products and benefits to meet the needs of your target audience. If you need help in putting your bid process together, call us today!
P.S. Take advantage of our Spring SALE! Sign up now for GHG's Sales, Marketing & Strategy consulting services and receive 10-15% off*. Project terms must be agreed upon by March 30, 2017, so don’t wait! Contact us today >> *Discount is based on client-specific defined scope of work.
Resources
The Medicare Advantage marketplace is evolving – are you prepared? Gorman Health Group’s marketing experts have developed strategic plans for hundreds of Medicare Advantage Plans, Prescription Drug Plans, Special Needs Plans and Exchange participants. We will work with you to understand your market, mining demographic data for opportunity and finding the gaps in the competitive field into which your plan can fit. Visit our website to learn more >>
The Gorman Health Group 2017 Forum Conference Brochure and Preliminary Agenda Is Now Available! Download it now to see the topics we have in store for you at this year’s event. Register now for the Gorman Health Group 2017 Forum, April 26-27, 2017, at the JW Marriott New Orleans.
Stay connected to industry news and gain perspective on how to navigate the latest issues through GHG’s weekly newsletter. Subscribe >>
How to Maximize Your Medicare Advantage Website Strategy
How was your Annual Election Period (AEP)? Have you evaluated your performance? Do you need to enhance your sales and marketing strategies? Now is the time to recognize and appreciate your 2017 successes as well as confront your shortcomings.
There are several moving parts to a successful sales and marketing strategy, one being your Medicare Advantage (MA) website. The internet shopping trend is ever rising and this now applies to MA. Baby Boomers are aging into Medicare and with them come a new trend in internet shopping, enrolling and communicating with not only family and friends but with organizations they receive goods and services. In the 2016 Age-In Study by Deft Research, we learn, “Internet shopping rates have surpassed the rates of all other shopping activities.” The days of only direct mail are in the rear view. In fact, we also learn that your direct mail is actually motivating your website visits. Take advantage of these trends and take control of your website strategy.[1]
Here are the top 3 items to keep in mind when evaluating, developing and implementing your MA website strategy.
- Think Easy: Your website mantra shall be: “clear and easy to navigate.” Not only is this the top requirement given to us from the Centers for Medicare & Medicaid Services (CMS) – in fact, this is the first requirement listed in section 100 of the 2018 draft Medicare Marketing Guidelines (MMG) – but this approach will ensure your website is user friendly and an effective marketing tool. Shoppers want the facts about your plan offerings and most importantly, they want them now. And if they are ready to enroll – the online enrollment process should just as easy as the shopping.Helpful tip: Organize your website around 3 general focus areas:
- Prospective member information – Here are your sales and marketing web pages, including the online enrollment tool.
- Current member information – These web pages focus on required content that is mostly geared towards your current members.
- Member Experience –Enhance your website with tools and a member portal that help drive your retention efforts.
- Follow the Rules: Make your list and check it twice. Compliance is key and whether you are developing, revising or monitoring your website, it is critical that you and your team have an understanding of all the CMS requirements as they apply to your MA website.Helpful tip: GHG recommends creating a website checklist that includes all CMS requirements. Are you developing a new website? List these requirements out as they would impact each of your proposed web pages or section of the website (prospective, current, retention). This is your content development driver. Are you revising or monitoring your website? This checklist is your tool to ensure compliance and it documents where each requirement is met by URL tracking.
- Member Perspective: It’s all about that member portal. As the Deft study highlights, web is worth it. Ensure an easy transition from prospect to member by providing your membership with an online, password protected member portal. Here the possibilities are endless – think newsletters, healthcare/health service reminders, provider/pharmacy look-up, drug search, claims check.Helpful hint: Collaborate with Stars! The experience of your members directly impacts your Star Rating. Collaborate with your Stars and care management teams to develop a member portal that truly supports member needs while simultaneously moving the numerator of your Stars measures.
Finally – don’t forget about your third-party websites. You may not have much control over the look and feel of your third-party websites but you must ensure they are compliant. Take note that one of the major changes proposed by CMS in the 2018 draft MMG is the addition of section 100.7 on third-party websites. CMS expects plans to be monitoring these sites in addition to their own.
All in all, enhancing our sales and marketing strategies is found in understanding our successes and failures. Take advantage of the rise in internet shopping and develop or revise your MA websites to go beyond the compliance requirements but to sell your products and retain your members. We are here to help!
[1] Deft Research, LLC. (n.d.) Marketing to Medicare Age-Ins: Internet and Direct Mail Trends. Retrieved from deftresearch.com
Resources
On Thursday, February 9, from 2-3 pm ET, join John Gorman and colleagues Olga Walther, Senior Legislative & Policy Advisor, and Leslie Mullins, Senior Consultant, as they provide a hard-hitting analysis of critical areas addressed in the document, including CMS’ changes to risk adjustment and encounter data, Star Ratings, Benefit Parameters and Bid Requirements, Part D Utilization Review, and more. Register now >>
The Medicare Advantage marketplace is evolving – are you prepared? Gorman Health Group’s marketing experts have developed strategic plans for hundreds of Medicare Advantage Plans, Prescription Drug Plans, Special Needs Plans and Exchange participants. We will work with you to understand your market, mining demographic data for opportunity and finding the gaps in the competitive field into which your plan can fit. Visit our website to learn more >>
The Gorman Health Group 2017 Forum Conference Brochure and Preliminary Agenda Is Now Available! Download it now to see the topics we have in store for you at this year’s event. Register now for the Gorman Health Group 2017 Forum, April 26-27, 2017, at the JW Marriott New Orleans.
Stay connected to industry news and gain perspective on how to navigate the latest issues through GHG’s weekly newsletter. Subscribe >>
Current Trends in Retiree Health Coverage Expected to Continue Under a Trump Administration
The landscape for retiree healthcare is not expected to change significantly under a first Trump term. However, several Republican proposals, if enacted, could incent group members to shift to the individual market over time.
Background - According to the September 2016 Kaiser Health Foundation (KFF) – Health Research & Educational Trust (HRET) Health Benefits Survey, 24% of large employers (200 employees or more) that offer health benefits to their employees still offer retiree coverage http://files.kff.org/attachment/Report-Employer-Health-Benefits-2016-Annual-Survey. Of the firms offering retiree coverage, 92% offer retiree coverage to early retirees and 72% to Medicare-eligible retirees. Over the past several decades, there has been a slow decline in employer coverage of retiree health benefits – down from 34% in 2006 and 40% in 1999. The 2016 level of 24% is similar to levels in recent years. Consistent with recent trends, employers are expected to continue to gradually reduce retiree coverage, but most employers that offer retiree coverage are expected to continue to offer this coverage in the next several years.
Impact of the Affordable Care Act (ACA) on Employer and Retiree Coverage – Use of the ACA Marketplace by employers has been low. The 2016 KFF-HRET Survey found only 17% of large firms offering retiree health coverage are considering shifting to Marketplaces that offer subsidies, which was lower than the percentage in 2015 (26%). So if the Marketplaces are repealed or substantially modified, the impact on employers should be small.
If the employer mandate is repealed, the penalties and much administrative burden on employers will be eliminated. This change would provide more flexibility on how retiree benefits are offered and could result in delaying any reduction in retiree offerings.
If the 40% employer Cadillac plan excise tax is repealed, more employers may retain their current retiree coverage and not follow in the footsteps of employers that have already acted to mitigate the Cadillac plan provision, e.g., switching to a lower cost plan, increasing cost sharing, selecting plans with a smaller network, or moving benefit options to account based plans. However, if an alternative price proposal to enact a cap on the annual tax exclusion for employer-sponsored benefits is enacted (e.g., $8,000 individual and $20,000 family), then employers may modify their plan designs and offerings.
Impact on Medicare Advantage (MA) Plans – MA Employer Group Waiver Plans (EGWPs) should continue to grow in markets that have not been fully penetrated over the next several years.
Defined Contribution Plans – In recent years, some employers have moved towards defined contribution plans, sending retirees to the individual market to choose a plan rather than remain in the group market. This trend has been smaller than predicted. In 2016, only 6% of large firms (200 or more workers) offering retiree health benefits report offering benefits through a private exchange, similar to the percentages in 2015. According to the KFF survey, an additional 21% of firms were considering a defined contribution approach. Assuming the individual market remains sound, some employers may move to a defined contribution in the future, thus eroding the employer group market over time. Some Republican proposals could spur this trend. For example, Tom Price’s 2015 repeal and replace bill (H.R. 2300) included a proposal that would cap the tax exclusion for employer provided benefits and permit employers to contribute to an employee or retiree plan in the individual market. If enacted, the proposal could make shopping in private exchanges more attractive and/or cause employees to leave the employer group plan because there would be more plan choices available.
Account Based Plans (Health Savings Accounts) – Many employers offer an account based plan, such as a Health Savings Account (HSA) or a Health Reimbursement Account, as part of their group coverage. A Trump administration is expected to pass legislation and regulations to allow more flexibility in these plans, and they can be expected to grow. For example, Tom Price’s 2015 legislation included a provision that would provide a one-time $1,000 tax credit for HSA contributions, increase HSA contribution limits to the maximum individual retirement account limit, broaden coverage of drugs before the deductible, and provide credit for over-the-counter (OTC) medications and fitness/nutrition services. Under the Price proposal, Part A Medicare beneficiaries would be allowed to contribute to HSAs while Medicare beneficiaries with Parts A and B could contribute to an Medicare Medical Savings Account (MSA) plan. While this change could make the MSA more successful than in the past, it would not address the small percentage of beneficiaries who understand the product and would be willing to move from a product that provides first-dollar coverage.
Resources
The Gorman Health Group 2017 Forum Conference Brochure and Preliminary Agenda Is Now Available! Download it now to see the topics we have in store for you at this year’s event. Register now for the Gorman Health Group 2017 Forum, April 26-27, 2017, at the JW Marriott New Orleans.
Stay connected to industry news and gain perspective on how to navigate the latest issues through GHG’s weekly newsletter. Subscribe >>
January Release of the Draft MMG - Perfect Timing
It’s still January, and, yes, the Centers for Medicare & Medicaid Services (CMS) has released the draft 2018 Medicare Marketing Guidelines (MMG). Perfect timing! The Annual Election Period (AEP) has come and gone, and here we are once again, having post-mortem discussions on what went right, what went wrong, and where to go from here. Once you have gathered all the necessary data, the next logical step is to begin planning for 2018 and revising your sponsor and organization strategies for Sales and Marketing. Don’t forget to review and provide feedback to CMS on the draft MMG changes. Although there weren’t many major updates (CMS provides mostly clarifications this year), there are a few key items that we highlight below:
- 30.5.1 – Multi-Language Insert
CMS essentially removed the standard Multi-Language Insert (MLI) section we have all become familiar with and defers to the requirements under Section 1557 and all questions to the Office for Civil Rights (OCR). Given the many interpretations of Section 1557 compliance and the confusion we saw around implementation of these requirements, it should be interesting to follow industry updates now that CMS is deferring sponsors to consult with OCR. Now more than ever, make sure your organization understands the requirements, documents the implemented process adopted within your organization, and consistently and compliantly operationalizes this process.
- 50.4 – Disclaimer on Availability of Non-English Translations
Previously, sponsors which met the five percent threshold for language translation were required to include the applicable disclaimer on all marketing materials. In the MMG draft, CMS updates the disclaimer and simplifies the requirement to a set list of documents only: Annual Notice of Changes/Evidence of Coverage (ANOC/EOC) or EOC, Low-Income Subsidy (LIS) Rider, Formularies, Star Ratings, Summary of Benefits (SB), and the Part D Transition letter. In addition, CMS proposes requiring the non-English translation of the disclaimer only – the English version is no longer required. Consider this draft change as you prepare marketing materials for 2018.
- 70.11.2 – Provider Affiliation Announcements
Here, CMS clarifies sponsors and/or contracted providers may not announce new or continuing affiliations until the contractual agreement has been approved. If implemented in the final MMG, organizations will need to ensure contractual agreements are complete and approved before any announcements of the relationship are published. CMS removed some announcement parameters from the section as well. For example, CMS previously stated announcements could be made once within the first 30 days of new contract agreement. Since this implied the contracts needed to be in place, clarification was needed to the section since they removed the sentence which limited the number of announcements. Also, CMS reminds sponsors affiliation announcement materials that contain benefits, premiums, or cost sharing are considered marketing materials. It is up to the sponsor to ensure providers adhere to distribution and mailing guidance.
- 100.7 – Third-Party Websites
Brand new section to the MMG! Sponsors are now required to submit third-party marketing websites that contain plan names or logos, even if there is no benefit information included, to CMS’ Health Plan Management System (HPMS). This includes any online forms that need to be filled out to receive more information about Medicare Advantage (MA) or Part D plans, including generic forms used to obtain information about non-MA or Part D plans. CMS includes that third-party websites may not:- Request health status information, such as pre-existing conditions, weight, and whether a beneficiary smokes;
- Provide misleading information, such as identifying a Medicare Supplement plan as an MA plan;
- Use prohibited terminology, including unsubstantiated absolute superlatives.
This list looks like it is made up of no-brainers and is consistent with requirements, but chances are, CMS has included this in the draft MMG because it is occurring in the industry. When preparing your website development, review, and submission schedule for 2017, don’t forget to include your third-party marketing websites. This will be on CMS’ radar, and it is up to the plan sponsors to ensure compliance of their third-party marketing website vendors.
- 120.4.1 – General Rules Regarding Compensation
CMS adds new language to this section indicating that plans may not pay agents/brokers who have not been trained and tested. If implemented in the final MMG, organizations will need to update payment processes to ensure agents who have not passed the training and testing are not paid.
The above is not an exhaustive list of the draft 2018 MMG updates. CMS is specifically requesting comments and questions from plan sponsors on proposed updates on provider affiliation announcements and third-party websites. Consider how this will impact your organization, and be sure to take advantage of CMS’ request for comments!
In addition to the release of the draft MMG, another hot topic we must also consider for our 2018 planning is provider directory accuracy. Last week, 21 Medicare health plans were warned to fix their provider directories – 18 warning letters and 3 warning letters with a request for a business plan to outline efforts to correct errors. In addition, 31 notices of non-compliance were delivered. Plan sponsors must have compliant directories. As recently as January 17, CMS released a memo titled “Provider Directory Policy Updates,” reiterating existing policy but also providing additional guidance. Don’t fall short on this – it’s no easy task and cannot be taken lightly. Spend time on this topic and develop robust data gathering techniques to keep your directories accurate.
Not sure how best to plan for 2018 or decide which strategies are best for you? This is not a one-size-fits-all industry, and we are here to help. Let us partner with you in developing appropriate, compliant, and effective sales and marketing strategies.
Resources
Don’t miss our webinar on Tuesday, January 31, at 1:00 PM EST, where we will provide an informative session on how to conduct a feasibility study to develop a successful growth strategy for your organization. Register now >>
The Gorman Health Group 2017 Forum Conference Brochure and Preliminary Agenda Is Now Available! Download it now to see the topics we have in store for you at this year’s event. Register now for the Gorman Health Group 2017 Forum, April 26-27, 2017, at the JW Marriott New Orleans.
Stay connected to industry news and gain perspective on how to navigate the latest issues through GHG’s weekly newsletter. Subscribe >>
It’s Product, Benefit, and Premium Time for 2018
Whether you are just updating your current product benefits, are offering a new plan benefit package (PBP), new product, or service area, or are new to Medicare Advantage altogether, now is the time to start planning for the 2018 bid submission.
It is best practice in the bid process to utilize a working team approach, with one clear leader. The team should include representatives from the following areas to ensure the best product is brought to market, and, when it is offered, that the implementation of the product is seamlessly implemented. Some of the members who should be included are:
- Sales/Marketing
- Finance/Actuary
- Network
- Pharmacy
- Medical and Health Management
- Operations
- Compliance
GHG believes, at the beginning of the bid process, it is important to level-set the team on the marketplace. Some of the analyses we typically like to present include:
- Service area demographics
- Medicare penetration
- Current membership analysis
- Enrollment trend analysis
- Results of the Annual Election Period (AEP): Who are the winners and losers this AEP, and why?
- Product analysis
- Benefit analysis
- Competitive analysis
Strong planning is key in the bid process. You want to understand the goals upfront and make sure your product and benefits can deliver. We have found weekly meetings, a detailed project plan with strong leadership, and project management skills are critical if you want to limit the number of iterations and last-minute back and forth that brings along the increased risk of errors.
Having a strong operations component incorporated in the process helps identify the planning needed to seamlessly implement benefit changes and pinpoint impacts on customer service. The Sales and Marketing team are key in characterizing product differentials and how the benefits will be sold, and not only how the sales team will sell, but if the Sales team can sell the benefits.
We could go on, but you get the importance of every department working together and pulling their weight. GHG has seen the success of plans who get the need for a deliberate process, as well as those plans in nail biting situations – hoping it all comes together at the end. Let me tell you, the first way is always preferable! So get your analysis started, put your project plan together, and start putting together your team if you haven’t already!
Resources
Don’t miss our webinar on Tuesday, January 31, at 1:00 PM EST, where we will provide an informative session on how to conduct a feasibility study to develop a successful growth strategy for your organization. Register now >>
The Gorman Health Group 2017 Forum Conference Brochure and Preliminary Agenda Is Now Available! Download it now to see the topics we have in store for you at this year's event. Register now for the Gorman Health Group 2017 Forum, April 26-27, 2017, at the JW Marriott New Orleans.
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Opportunities for Growth in the New Administration
"Opportunities are like sunrises. If you wait too long, you miss them." ―William Arthur Ward
With the new administration coming into power this month, there is a lot of conjecture over what might happen. Overall consensus is the one business segment that is the most stable is Medicare Advantage. Trump is a supporter of Medicare Advantage, and so are Republicans, although long-term there is an opportunity to change the financing of premiums. The Marketplace (Obamacare) and Medicaid are in “limbo” until we get a better idea of what and when there will be changes and how drastic they will be for these programs. So if you are looking for growth in revenue and/or enrollment, Medicare Advantage can provide a good opportunity. The other good news is that in the past several years, the Medicare Advantage market has been stable, based on the metrics available, with few changes in average premiums, plan offerings, and insurer participation.
If you are looking at the opportunity to grow or expand, there are many parameters to consider. Whether you are a Medicare Advantage plan considering expanding either your service area or products, Medicaid plans looking to add either Medi-Medi plans or Special Needs Plans, or an Accountable Care Organization or Integrated Health System looking to jump into Medicare Advantage, now is the time to explore this opportunity. Many of our clients are finding the most prudent way to expand and grow is a strong, solid strategy and an implementation plan that begins with a feasibility study.
A feasibility study looks at the market, and that analysis helps to build a strategy going forward for three to five years. This analysis looks at the competitive, financial, and demographic factors of a market(s) to see what is the most viable. This leads to a feasibility model based on detailed financial projections, and Gorman Health Group’s feasibility study process utilizes an onsite strategy exploration to walk through the entire process of entering Medicare Advantage or expanding current products and service areas with an emphasis on risks and rewards. The next step is the development of product/network/benefit design and implementation phases to build a competitive and compliant organization with the proper financial and operational controls in place. Even existing plans need a new perspective to manage member retention, risk adjustment, and overall analytics to support an integrated care organization.
No matter what your situation, this opportunity could be your sunrise, so don’t wait and join us for our webinar on January 31, 2017 at 1:00 PM EST for an informative session on how to conduct a feasibility study and taking it to the next step. Register now >>
Resources
Stay connected to industry news and gain perspective on how to navigate the latest issues through GHG’s weekly newsletter. Subscribe >>