Leavitt's Take on ObamaCare Mirroring Medicare Part D
Former UT Governor and Bush HHS Secretary Mike Leavitt had a terrific op-ed recently in the Washington Post examining similarities and differences between the launch of ObamaCare's health insurance exchanges and implementation of Medicare Part D in 2006. As always, Mike's insights are on-point and a rare constructive voice from the right on how to actually improve the program's takeoff.
Leavitt says at one point, "I'm not hoping for a wreck. That outcome would hurt ordinary people, not just politicians." That's a bold statement from a GOPer these days. When was the last time you heard an elected Republican official say anything other than "wreck and repeal" about ObamaCare? To the point, the Post had another piece on how many House Republicans, like Reps. Tim Huelskamp and Jason Chaffetz, have said flatly they will deny any assistance to constituents who call their offices looking for assistance with the law. So from that standpoint Mike offers a fresh perspective that will hopefully change some minds in the lower chamber and maybe a few statehouses.
Mike points out the extensive parallels between ObamaCare and the launch of Part D. Both were the result of fierce fights on the Hill and involved the creation of a heavily-regulated insurance market from a green field. Both suffer from an uninformed public and heavy opposition. Both involve data exchange on eligibility and enrollment that are enormously complex. The team writing the ObamaCare regulations are mostly folks from the Medicare Advantage and Part D offices of CMS, and they're building a system based on that experience. But the similarities end there, and Leavitt offers some insights into how the Administration can avoid the "train wreck" we've been hearing about is coming.
Leavitt is right that the challenge of a misinformed public and insufficient education and outreach is enormous: "With the ACA's initial enrollment period three months away, 78 percent of Americans lack awareness about the law and the changes it will bring. Four in 10 don't even know the law is set to take effect." He then details the PR effort he engaged in on Part D as HHS Secretary. But he's understating things here. The education push on ObamaCare will be hampered by unprecedented political opposition at both state and Federal levels:
- At the Federal level, Congress barely appropriated 10% of the Administration's request for Navigators, the impartial enrollment counselors, and are fighting all agencies who intend to help -- like the Education Department distributing brochures through libraries. The kinds of PR activities Mike engaged in as Secretary to support the Part D rollout would earn Secretary Kathleen Sebelius a Congressional subpoena today.
- At the state level, remember, the states were bought in on Part D as it shifted their Medicaid drug spend for dual eligibles to Medicare with only a maintenance of effort. Roughly half the states have rejected the ObamaCare Medicaid expansion and refused to build their own health insurance exchanges. Many of those states are actively resisting any participation in outreach or education.
So from the standpoint of public awareness, this is a huge difference between ObamaCare and Part D and it has a lot to do with the blind opposition of Leavitt's own party.
Next, Leavitt speaks to technology breakdowns and subsidy errors, pointing out rightly that the successful launch of ObamaCare is dependent in part on the "data hub" that will connect and transfer eligibility and enrollment data among health plans and several Federal and state agencies. He's correct on this point, too, but again, doesn't go far enough in illustrating the challenge.
CMS's own data systems to manage Part D and their interaction with the plans' systems created a hot mess that persisted through much of 2006. It was the seemingly-simple-but-insanely-complex task of getting "the pig through the python" of health plan enrollment shops, where people and processes got overwhelmed and applications piled up or got pushed through with human errors. The result was months of confusion and work-arounds as seniors arrived at pharmacies and couldn't access their benefits. This was after a year's worth of training camp in 2005 we called the Medicare discount drug card that served as a bridge to the "real" Part D.
ObamaCare's launch will be much more complex and therefore more prone to benefit-denying errors. There's no training camp for the exchanges. The eligibility and enrollment process is much more complex than Part D given the income tests that determine the amount of your subsidy and the number of agencies involved. And remember: Part D is a benefit; you qualify, pick a plan, get a member card, and most seniors opted to have their premiums deducted from their Social Security checks. The exchanges are all about the subsidy, which determines which plan you can afford. If CMS gets the subsidy wrong, it's a confidence-sucking hassle, and they couldn't try to claw that money back from low-income beneficiaries. And the workaround for those who don't have bank accounts to push the subsidy into makes your head spin. Every quandary will have a human story -- and right-wing media and social outlets like Twitter barely registered in 2006. In 2014 the news cycle and online vitriol will make each tragic story seem pervasive -- and the resulting "white noise" will get in the way of the outreach and education effort.
Finally Leavitt closes with advising ObamaCare policymakers to assume full responsibility for the mess to come. He recalled a briefing he gave to Senate Finance members on status of the Part D rollout. He spoke candidly about challenges and the Administration's plans to fix them, by when -- "candor bought us time," he says. This time around, candor will buy you a subpoena and endless finger-wagging from the talking heads.
Mike Leavitt is one of my favorite Republicans, but my friend dropped a whopper at the conclusion of his otherwise excellent op-ed: "The ACA reflects the belief that government should play a much bigger role in making our health-care decisions, while the drafters and implementers of Part D held the view that government's role in health care should be limited to organizing a system of competition, where consumers are empowered to make choices and are protected from unfair treatment."
Sorry, Mike, but the exchanges emerged from the conservative Heritage Foundation as just that: a system of regulated competition, modeled after Part D. I don't see a much bigger role for the government in making our healthcare decisions in ObamaCare, just a much bigger undertaking with a Presidency at stake.
Resources
The rapid changes to Part D regulations make the tracking and implementation of these CMS requirements exceptionally difficult. Visit our website to find out how GHG can help.
GHG's Founder and Executive Chairman John Gorman addresses the critical issues issuers must address before the launch of the Exchanges in this recording from the 2013 GHG Forum, June 13-14 in Washington, DC.
Join us on August 13 and hear GHG's Chief Development Officer, Aaron Eaton, and Independence Blue Cross' Senior Vice President of Health Care Reform Implementation, John Janney, walk through an operational readiness checklist to help make sure your health plan is ready to go live on October. 1.
Now the Blood is in the Water
Last week, the Obama Administration issued a notice that the Affordable Care Act's (ACA) "pay or play" employer mandate and reporting requirements, which were set to take effect on January 1, 2014, are being postponed until 2015. Now the blood is in the water with all of Washington asking "what's next to be delayed?" It's not even clear the Administration had the legal authority to delay a provision of the law. While not a big deal for most employers or payers -- most employers already offer comparable coverage to full-time workers -- the political ramifications are huge.
This postponement means that an employer won't be penalized if it does not offer its full-time employees affordable health insurance in 2014 that's comparable to what will be offered in the exchanges -- with a penalty of $2,000 per full-time employee. The ACA also requires health plans and employers to report certain information on health insurance coverage to the IRS in 2014. The Administration also postponed this reporting requirement until 2015, though it still encourages these entities to voluntarily report coverage information in 2014. Like that'll happen.
Predictably the business interests that fought for the delay had nice things to say for the Administration's decision. "I think this is less about readiness and more about the fact that they're trying to be flexible in their implementation," said Rhett Buttle, Vice President of the Small Business Majority, which supports the ACA. "It does seem like an olive branch." But less charitable business interests will see this victory and will start lining up for additional concessions.
The implementation of the rest of the Act, including the health insurance exchanges, individual mandate and other reporting requirements, are unaffected by the announcement and, at least for the moment, are proceeding on schedule -- until they're not.
The event seems to be bolstering the arguments of both sides of the health reform chasm. The ACA's opponents just got their sneering "I told you so". They say the delay is Obama's admission of the law's failures, and once again the "repeal and replace" chorus just warmed up for another show. White House Senior Adviser, Valerie Jarrett, defended the delay as listening to employer concerns.
We can't lose sight of the fact that this is the second major delay in the implementation of ObamaCare, and it's playing right into the Congressional Republican narrative that the Administration can't get its act together and that this is going to be one hot mess starting in October. HHS Secretary Sebelius better have her own Capitol Hill parking spot lined up.
Resources
Read Gorman Health Group's recap of the 2013 GHG Forum, which includes details regarding preparing for the health insurance exchanges. This free download is available on the Point.
The ObamaCare Enrollment Push Begins
So we're less than 100 days away from the official launch of outreach and marketing for the new Health Insurance Exchanges, and the enrollment push began in earnest this weekend. It's happening in the face of some tremendous headwinds unlike anything seen since the launch of Medicare Part D in 2006, maybe ever. The Medicare drug benefit' s takeoff didn't have to contend with furious political opposition at both state and Federal levels, a horribly misinformed public, and the demographic challenges of ObamaCare.
Enroll America, the Obama-driven leftie coalition that's tasked with pushing enrollment in the exchanges, kicked off its boots-on-the-ground effort last week. Enroll America President Anne Filipic told POLITICO today that the first week went well as the group tried to change the conversation from politics to benefits. They had 1,000 volunteers out, 1,000 on a strategy call, 78 events in 25 states (they expected to do 50 in week one), and knocked on 3,200 doors. Not a bad start for a group that sprung from Obama's legendary campaign ground operation.
Changing the debate from politics to benefits is no small task for the pro-ObamaCare forces in the field. Health and Human Services Secretary Kathleen Sebelius has been getting slammed for her fundraising calls on behalf of Enroll America to industry stakeholders like insurance companies. Last week 28 GOP senators sent a letter to HHS Secretary Kathleen Sebelius asking her to "immediately stop" fundraising for Enroll America until she has answered more questions about it.
Then Sebelius called all the professional sports leagues last week to seek their help in outreach to potential ObamaCare beneficiaries this fall -- and Congressional Republicans wailed again. Senator Minority Leader Mitch McConnell (R-KY) and Senator John Cornyn (R-TX) wrote "Given the divisiveness and persistent unpopularity of the health care [law], it is difficult to understand why an organization like yours would risk damaging its inclusive and apolitical brand by lending its name to its promotion," in letters sent to the commissioners of the NFL, MLB, NBA, NHL, PGA and NASCAR. It appears most if not all of professional sports will not participate. It's too bad -- I loved the speculation of what the ads might look like.
All of this is of course happening against a backdrop of a terribly misinformed public, especially among uninsured prospective ObamaCare beneficiaries. An April Kaiser health tracking poll found 42% of Americans are unaware that the Affordable Care Act (ACA) is still the law of the land, including 12% who believe the law has been repealed by Congress, 7% who believe it has been overturned by the Supreme Court, and 23% who don't know whether or not the ACA remains law. And about half the public says they do not have enough information about the health reform law to understand how it will impact their own family, a share that rises among the uninsured and low-income households.
The biggest problem the ObamaCare rollout faces, though, is demographic. First, many ObamaCare eligibles are low-income, and not necessarily English-speaking. They may not see or understand ads on English TV channels this fall, and they'll need different messaging, outreach and hand-on counseling at the kitchen table. And with Congress literally appropriating 10% of what the Administration requested for insurance Navigators to help the uninsured through the enrollment process, and literally dozens of Red State governors in opposition and of no help on the ground, that's a tall order for Year One. CuidadoDeSalud.gov is getting a makeover this summer, and HHS announced it has opened its 24/7 call center, which is supposed to be able to handle millions of consumers' questions in 150 languages.
Second, the viability of the exchanges rests on risk selection, and that means if we don't get the "young invincibles" and the "bro's" to sign up to offset the risk of the sick uninsured we know will flock to the program, we'll fall into a rate-setting death spiral. The Administration is looking for 7 million enrollees in Year One, including 2.7 million young adults. And there's actually some encouraging news here: Kaiser's poll found more than 70% of those under 30 said that having health insurance is "very important," something they need, and that it's worth the money. Overall, just a quarter of those ages 18-30 feel they are healthy enough to go without insurance. Doesn't necessarily mean assured enrollment, but it is a ray of hope through all the white noise.
Things are sure to get Presidential campaign-level crazy right after Labor Day, when the Administration is convinced folks will start paying attention. Expect a blizzard of pro and con communications across every medium imaginable, and millions of confused uninsured consumers in between.
Resources
Read Gorman Health Group's recap of the 2013 GHG Forum, which includes details regarding preparing for the health insurance exchanges. This free download is available on the Point.
Listen to a GHG podcast from GHG's Executive Vice President Steve Balcerzak regarding the unbanked and the uninsured, and the implications this population will have on ACA enrollment. This podcast is freely available on the Point.
GHG policy expert Jean LeMasurier provides an overview of key takeaways from CMS' proposed rule that establishes financial integrity and oversight standards for Health Insurance Marketplaces, QHPs in FFMs, and states that operate risk adjustment and reinsurance programs. This regulatory summary is available to members of the Point.
Agent Oversight Improves Quality and Customer Experience
If you're like most health plans, you rely on key "glue folks" to keep operations running smoothly. You know the ones: staff members that embrace their role, mind the details and ensure behind-the-scene efforts improve outcomes. They may or may not communicate one-on-one with customers, but their efforts contribute in a positive way to the overall customer experience.
For many, the partners and team members that manage the oversight of field and call center agents are the very glue of the sales and marketing activities inside a plan.
Consider agent oversight in three parts: Compliance, Operations and Quality. They're three distinct functions of equal importance. When synchronized, Agent Oversight aids in seamless performance of an organization's sales and marketing efforts.
What do we mean by three distinct functions? Consider the three-legged stool:
Compliance is more than a disciplinary function. The compliance department should work directly with Operations to ensure open channels of communication exist with all sales agents. Effective communication of regulatory requirements through training can mean prevention of compliance missteps and disciplinary actions.
Operations should be proactive regarding agent oversight functions. With careful monitoring of agents and frequent status reports, agent issues can be addressed promptly and directly. Simplify the process with technology to monitor sales meetings anywhere and anytime and assess agent performance in real time. Oversight recommendations may include additional training, corrective action or require immediate termination. Regardless the action, the result must be swift.
Quality programs should offer metrics on evaluating agent performance. There are a number of ways to rate agent performance in the development and implementation of Quality programs: grading, coaching or performance reporting. At Bloom, we use all of those tools — as well as call review, call scoring and calibration for each call center agent. Plans should work closely with their call center partner to develop, implement and assess a customized Quality program that best meets their needs. A strong partner can work with a plan to implement an existing program or to craft a new one.
Resources
The Bloom Call Center is licensed in 48 contiguous states and offers marketing, call center and technology solutions to the health care industry. Since 2007, Bloom has participated in over 55 million conversations about insurance products, submitted over 200,000 applications for insurance, and set over 150,000 appointments for seniors to meet with Licensed Agents. Bloom is a proud partner of Gorman Health Group. Click here to learn more.
Lessons from Part D for ACA Implementation
It was interesting to hear Mike Leavitt and Mark McClellan compare their experiences in launching the Medicare Part D program in 2005 and 2006 to the challenges facing HHS and CMS in launching the new Health Insurance Marketplaces at a recent Brookings Institution forum. There are so many parallels and yet important differences. The lessons from Part D are also discussed in a new report from Georgetown's Center on Health Insurance Reform funded by the Robert Wood Johnson Foundation.
Several of the parallels include:
- Outreach and Education Challenges — HHS began a public education campaign 15 months in advance of the Part D program including over 500,000 events and a bus tour by the Secretary and HHS officials. However at the start of enrollment 80 percent of beneficiaries reported they would not enroll or were uncertain about enrolling. 100 days before the Marketplace open enrollment period, HHS is just beginning its outreach program and they are using successful techniques from the Part D program, e.g. extensive use of partnerships and local events conducted by Regional Offices. However, funding for the ACA educational efforts is limited, timing is shorter, and HHS does not have a list of the target population for the individual marketplaces since they do not currently have insurance. Social media offers a shortcut to reaching a key target audience, the 18 — 35 year olds, who are essential to keep premiums affordable. However the challenge will be the messaging. HHS is hopeful that they will be able to build a culture of coverage with the offer of access to an insurance card for the first time and the encouragement from Mom.
- Public Skepticism — The lack of public support for health care reform has been consistently documented by the Kaiser Family Foundation surveys. However the recent discussions remind us that public opinion was actually less favorable for Part D where only 21 percent of beneficiaries had a favorable opinion in April 2005 compared to 35 percent with a favorable opinion of the ACA in April 2013. Mike Leavitt observed that now the sides supporting the change have reversed. A big difference in Part D was that the penalties for not enrolling carried on forever, thus spurring last minute enrollment. The ACA penalties are comparatively smaller and will not provide the same incentive. That will mean that we will need a longer window to assess ACA performance as enrollment continues to grow over a multiple year period.
- Plan Participation and Costs — CMS officials worried that stand alone drug plans that did not exist in the private markets in 2005 would not sign up to participate in Part D. There was also controversy about the cost and affordability of the premiums. It turned out that there probably too many choices under Part D and costs came in below projections. There are similar worries about plan participation in the Marketplaces. CMS reports that 120 plans applied to the Federal Marketplace, however participation in the state marketplaces is more uneven and particularly low in the SHOPs with no plans in the Mississippi SHOP and only 1 plan in the North Carolina SHOP. Most of the plan premiums have not been released, however early reports suggest that there will be variation by marketplace and the number of competitors. A study of 9 states by Avalere shows rates lower than CBO predicted. However, we have also read about an average 25 percent increase for plans in Maryland. HHS will post final rates in the FFM in September, although some states may release final rates in late summer.
- Market Readiness — Despite short timeframes, CMS was ready for enrollment in November of 2005, but we all remember the anecdotal stories of beneficiaries who showed up at pharmacies on January 1 unable to get their drugs. Fortunately, the states came to the rescue and the glitches were ironed out over time. The same concerns about operational readiness face the implementation of the ACA where the number of potential enrollees is higher, the systems more complicated and the subsidies more complex. The longer enrollment period will provide more time to iron out any problems. However, most states will not be willing or able to jump in if the federal roll-out stumbles.
Resources
Listen as Whitney St. Jean, Chief Administration Officer of Gorman Health Group, outlines the components of a successful go-to-market strategy for MA plan sponsors and their partners.
The rapid changes to Part D regulations make the tracking and implementation of these CMS requirements exceptionally difficult — to say nothing of actually managing to them, find out how GHG can help.
Gorman health group can help position you for the challenges—and opportunities—posed by health reform, designing a strategy that takes into account your service area, market environment, core competencies, and vision of the future, click here to find out how.
Humana's CEO on Implementing ObamaCare
Reuters got a nice scoop with Humana CEO Bruce Broussard, who took over from the legendary Mike McAllister in January, with an interview on their approach to implementation of ObamaCare in less than 100 days. It was good enough to reprint in full below. A couple impressions:
- Broussard points out how much the industry wants the launch of ObamaCare to NOT fail. Congressional Republicans could take a lesson: the time for foaming-at-the-mouth opposition is over -- it's time to roll up our sleeves and make this thing work for the good of the country.
- The comparisons to the launch of Medicare Part D, which Humana dominated with United, are appropos. There will be mass confusion and disruption in the system as outreach and marketing begin in October. There will be horror stories of administrative meltdowns keeping sick people from benefits. But it will work itself out in the latter half of 2014 and will become immensely popular. Let's just hope an eligibility screwup doesn't kill someone next year -- the media frenzy will be fueled by the reporters' credo to "afflict the comfortable and comfort the afflicted," and there's nothing more afflicted than a sick American thwarted by governmental or corporate ineptitude.
- Humana was brilliant is deploying its veterans of the Medicare Advantage and Part D wars earlier this decade to the front lines of ObamaCare. The similarities between the programs are stunning and the company is way ahead of most of its competitors by leveraging their own vast experience. Most plans made the mistake of thinking "individual = commercial" when it came to product strategy; the reality is that the exchanges will much more closely resemble government business, with much sicker enrollees and more administratively complex systems to reconcile.
- Note Humana's retail strategy at the conclusion of the interview. That's the same playbook that won the day on Part D: "wallpaper" presence in places like WalMart. It'll have the same result in the 14 states they're chasing exchange business in.
Humana's CEO on the massive undertaking of health reform
By Caroline Humer
(Reuters) - Bruce Broussard took over as chief executive of Humana Inc in January, just in time to steer the health insurer's entry onto the health insurance exchanges created by President Barack Obama's reform law.
Humana plans to sell subsidized insurance plans in 14 states, including Arizona, Colorado, Florida and Kentucky, where it is based, about the same number of states as rivals like WellPoint Inc and Aetna Inc.
The exchanges are expected to bring in 7 million people in 2014. Insurers must offer plans to any individual who applies, regardless of prior health problems. The government will provide subsidies to people who earn up to 400 percent of the federal poverty level, or $94,200 for a family of four.
Humana already has experience with government healthcare programs - it has more than 2.5 million members in privately administered Medicare Advantage plans for the elderly. It also manages Medicare pharmacy benefits for more than 3 million people.
Here is a discussion that Reuters had with Broussard this week on the effort to roll out "Obamacare":
Q: What has proven harder than you thought about the development of the exchanges?
A: This is a massive project. A number of months ago the industry met with the president and he made the comment this is probably the largest healthcare project since the Truman-Kennedy era, and he is right. We are taking on a very, very large project and so there are a lot of details that the states and the federal government are working on. It's keeping up with those and being able to implement them where they are already behind schedule, and trying to keep up so that we do fulfill the needs of the public promise that has been made.
Our challenge right now is it is moving so quickly, keeping up with it and being able to assist the state and federal governments for it to be successful because I think the last thing we want is for it not to be successful. So we are dedicated to helping it. But the details are coming out and they are coming out as quickly as the federal government can get them out.
Q: What did you think about the recent U.S. Government Accountability Office report that said some states are behind?
A: I'm not going to take a different stance than the GAO. I'll just say in general there are a lot of details and everyone is working hard to get this done. The industry is working hard, the states are working hard, the federal government is working hard, but this is a big task that's been taken on and I'm sure details will be get lost in the process just because of the size and the enormous effort that is required here.
Q: When consumers decide on which plan to purchase, would you expect that access to certain doctors and hospitals will play a large role?
A: It's going to be interesting. This is where price and choice are going to come at a crossroads here. I think a more cost-effective product is going to have less choice. It is a test. Most of our products are going to be narrow networks and limited providers because we feel that is the best way we can offer a product that is going to be cost-effective.
Q: How else can consumers judge the value of these products?
A: This isn't much different from (Medicare) Part D and Medicare Advantage when it came out in 2005. There was a lot of confusion around what it meant and there was a lot of time being spent on educating both around choices and options and subsidies to the type of plan.
As we look over the coming number of months, we look at that as a responsibility that we have in educating in the 14 states we will be in. We are going to take our market point sales group that today also handles the Medicare Advantage program, we are going to expand that and they will be an active part of the individual exchange. So we are going to have people on the ground helping people.
We also believe in having relationships where people are in their normal course of life, so retail chains are an important part of that. So not only are we going to have people go to their homes, but in addition we are working with partners with retail outlets so we can staff individuals where it is convenient to a potential member to incorporate in their life.
Q: Do you mean grocery stores and pharmacies?
A: Yes, that's right.
(Reporting by Caroline Humer; Editing by Michele Gershberg and Douglas Royalty)
Resources
Gorman health group can help position you for the challenges--and opportunities--posed by health reform, designing a strategy that takes into account your service area, market environment, core competencies, and vision of the future, click here to find out how.
Listen to a three-part podcast series where GHG Executive Chairman, John Gorman discusses the Importance of a Readiness Checklist for the Exchanges for Sales Marketing Enrollment and Risk Adjustment.
Visit our website to learn more about how Gorman Health Group can help support your Medicare Advantage goals.
The rapid changes to Part D regulations make the tracking and implementation of these CMS requirements exceptionally difficult -- to say nothing of actually managing to them, find out how GHG can help.
Lake Wobegone Exchanges
One of the most frequent questions I've been getting on the health reform speech circuit has been what our expectations are for enforcement activity in the exchanges in Year 1 -- and the answer is just about none.
For the 16 states launching their own exchanges this Fall, much of the focus will be on basic administrative functions involved in getting the millions expected to enroll through the system. For the 27 states where the Federally-Facilitated Exchange will be operating, the answer is really nothing. The Feds are painting a picture of "Lake Wobegone Exchanges", where all of the plans are strong, all of the brokers and agents are good looking, and all of the stakeholders are above average.
Year 1 of the Exchanges was always going to be about getting the "pig through the python" of the enrollment and eligibility process. It was basic fulfillment functions like verifying "clean" enrollments, entering and reconciling new members into plans' systems, and issuing membership cards that tripped up the launch of Medicare Part D in 2006. The rollout of the Exchanges will see the same struggles. But CMS's latest rule points to an enforcement "hall pass" for participating plans in Year 1.
CMS's latest exchange regulation estimated that there will be more than 250,000 agents and brokers registered in the Federal Exchange -- and went on to say it expected to suspend or terminate 2. Not a typo. CMS seems to be saying that their agent oversight role is limited since states have primary responsibility for broker licensing and monitoring -- but still, 2 out of 250,000? Really? CMS further estimated there will be 409 Qualified Health Plans (QHPs) in the Federal exchanges, but only 1 civil money penalty and only 1 plan termination. Talk about a paper tiger.
CMS will not do much but play "whack-a-mole" with anything egregious that comes up in QHPs. There will be little to no unilateral state enforcement in the first couple years of the Exchanges. And there won't be any kind of organized compliance process for plans in the exchanges like we see in MA until at least year two or three. So bottom line: the plans don't have to worry about the hammer coming down in Year One -- unless they kill someone with an administrative screw-up. Lake Wobegone for sure.
Resources
Listen to a three-part podcast series where GHG Executive Chairman, John Gorman discusses the Importance of a Readiness Checklist for the Exchanges for Sales Marketing Enrollment and Risk Adjustment.
Learn how Gorman Health Group's web-hosted modular software solution, Sales Sentinel, makes sales agent training, credentialing, onboarding and ongoing oversight a smooth and seamless process.
When reconciling Plan data to CMS' records, you have to deal with a number of issues. Listen in as Gorman Health Group's Senior Consultant Chris Groves discusses these issues and the importance of reconciling member data.
Choosing a Call Center? Five Must-Ask Questions
This fall promises to be one of the busiest in history for health insurers with the flurry of Health Insurance Exchanges (HIE), Annual Election Period (AEP) and the implementation of the Affordable Care Act (ACA).
Unanswered calls to insurance companies by potential customers will become forfeited opportunities that may never be reclaimed. Many companies will rely on call centers to handle their call overflow, many for the first time. Consider these five questions when selecting a call center:
1. TECHNOLOGY: Does their technology meet your needs?
The complexity of the insurance industry calls for innovative technology solutions: practical solutions that improve the process for agents and customers alike, and proactive solutions that are flexible enough to handle diverse responsibilities in intuitive ways. Can their call center directly connect your callers with agents in the field instantly? Can they track responses at the individual record level? Do they offer dashboards and reporting in real time?
2. TRAINING EXCELLENCE: Are their CSRs well-trained on Medicare and your plan's protocols?
Harper Lee wrote in To Kill a Mockingbird, "We're paying the highest tribute you can pay a man. We trust him to do right. It's that simple." Like Atticus Finch, trust in the training call center agents receive is a key consideration in a partner. After all, they represent your Medicare plan(s), your brand and your relationships. Could your call center partner handle the scrutiny of a CMS audit?
3. AGENT EXPERIENCE: How experienced are their CSRs?
Exerience is critical in the insurance industry. Experienced agents could mean the difference between a successful sales campaign and a failed one. Because AEP is condensed, inexperienced agents shouldn't gain the necessary experience on the fly.
4. QUALITY & COMPLIANCE Is a robust quality and compliance program with metrics reporting in place?
Quality and compliance go hand-in-hand. Everyone's accountable to CMS. A good compliance program protects clients, plan members and prospective members alike.
5. ADAPTABILITY: How much flexibility and input is permitted?
Flexibility and adaptability are the bread & butter of a vendor partnership, particularly when responsibilities are outsourced. Will you have access to a support team when needed? Such access ensures seamless support of day-to-day campaign challenges. A high-quality support team is agile, adaptable and attentive to detail. Partnering with an experienced call center helps you stay competitive, provides excellent caller experiences, and helps grow your membership.
Resources
The Bloom Call Center is licensed in 48 contiguous states and offers marketing, call center and technology solutions to the health care industry. Since 2007, Bloom has participated in over 55 million conversations about insurance products, submitted over 200,000 applications for insurance, and set over 150,000 appointments for seniors to meet with Licensed Agents. Bloom is a proud partner of Gorman Health Group. Click here to learn more.
QHP Submission Reprieve
OK, so maybe reprieve is not the right word, since according to Google it is defined as "a cancellation or postponement of a punishment". If you consider a deadline a punishment, then I suppose this is a reprieve, but I digress.
HHS sent out an email Thursday night informing the industry that those issuers who have begun the QHP application process as of 8 pm, will be considered as having met the deadline. This was subtly inserted at the start of the third paragraph so look again if you missed it. This doesn't mean you should rest on your laurels; they expect everyone to attempt to correct and submit all required pieces by 8pm tonight.
Issuers who have completed submissions and would like to submit a petition requesting a Limited Corrections Window must do so by 9pm EDT (formerly 5pm EDT) on Friday, May 3rd by sending a signed letter to CMS_Issuer_Communications@cms.hhs.gov with the subject line "QHP Data Correction Request" and specific HIOS Issuer ID(s), as outlined in the instructions distributed on Monday, April 29th.
If you are trying to decide if you need to submit a petition, CMS states that if you are simply having technical issues with the uploading and the physical acceptance of your documents, then you do not need to do a petition, but instead you have a new window of this coming Monday until 11:59PM Eastern in order to try to get the system to accept your documents. (Remember, HIOS is down this weekend for maintenance.) According to how CMS is responding to Issuer questions on their Open Q&A call, it sounds like they want the petition process reserved for non-technical corrections on completed submissions, such as last minute content changes, or if you just received clarifying guidance and now need to change something that has already been submitted.
Issuers are asking "Well what if we still have technical problems on Monday and didn't submit a petition?" and "Will you have an Open Q&A call on Monday?" At this point, CMS is taking the "We'll-Cross-That-Bridge" stance, so stay tuned.
Resources
Don't let the application process get in the way of your organization's goals. Learn how Gorman Health Group can help ensure you have a smooth and compliant process.
So You Want to File a QHP Application
This will be the title of my instructional pamphlet that I envision sitting in a doctor's office, among other great pamphlets such as "Talking to Your Kids about Drugs" and "Depression: Not Just a Hole in the Ground".
Many of you reading this may also be in the midst of QHP uploading, on the receiving end of such terms as Error, Failure, Pending, and Invalid. Not what you'd call a walk in the park. I had a dream last week that President Obama himself told me personally that the QHP submission deadline would be extended. Anyone else required to eat, sleep and breathe this submission knows what I'm talking about. The message I'd like to send to anyone reading at CMS is this: we are trying. The industry is trying. We would be dismayed to see consumer choices limited due to trivialities such as technical errors.
That being said, my team is grateful for the additional days that CMS granted for the FFM submissions. If your organization falls short due to one of the reasons outlined in CMS' memo, make sure that you submit a detailed petition to CMS by 5:00 PM Eastern Time on Friday, May 3. It must be signed by an officer of the company and include:
- The specific data elements that need correcting
- The HIOS issuer ID(s) in question
- The reason why the data elements must be corrected
- Evidence that documents the issuer made timely and good faith attempt to address the issue at least 48 hours prior to the new deadline, that is, as of May 1, 8:00 PM Eastern Time. Help desk ticket numbers, screen shots, send it all.
Anyone willing to share their battle stories once you are on the other side of the deadline (Friday May 3 at 8:00 PM Eastern Time), feel free to email me. There's satisfaction in knowing you are not alone in Navigating this maze. (Yeah, you see what I did there.)
Resources
Don't let the application process get in the way of your organization's goals. Learn how Gorman Health Group can help ensure you have a smooth and compliant process.