There's a Lot to Like and to Fear in the 2017 Medicare Advantage Call Letter
On Friday after the close, the Centers for Medicare & Medicaid Services (CMS) released the 2017 Medicare Advantage (MA) Call Letter with proposed policy and payment changes. There's a lot to like — and much to fear. On payments, CMS came in with higher-than-expected rates that make clear the long walk in the desert from cuts in the Affordable Care Act (ACA) is over. But on compliance, they are rolling out the firing squad with a broad mandate, and the Administration will leave its mark long after Obama has left office.
What We Like:
- The draft offers all-in rates of +1.35% and a trend of +3.05%, better than last year and better than expected.
- CMS is leaving home visits for MA risk adjustment untouched. If ever CMS was going to clamp down on this after years of threats, this was the time — in the last year of the Administration. By not doing so, we think they're closing the book, acknowledging much good also comes from these house calls, and the home is the most underutilized source of care in the delivery system for seniors. Despite MedPAC recommendations and a drumbeat of op-eds, CMS didn't want to throw the baby out with the bathwater.
- There are big proposed changes to risk adjustment and Star Ratingsfor MA plans serving dual eligibles.
- CMS would launch a new payment system with six subcategories: full duals, partial duals, and non-duals, for both aged and disabled beneficiaries. The net effect is like a crude, mega-risk adjuster, paying plans with more duals bigger, more accurate payments, while paying slightly less to plans with fewer duals.
- On Star Ratings, CMS is proposing an adjustment on three key measures — the overall plan rating, and Part C and D summary ratings — which will increase ratings for plans with higher proportions of duals and could increase bonus payments if the plan is 4+ stars. This is a big win for the industry.
- The health insurer issuer tax has been suspended for a year (and will return in 2018).
What We're Worried About:
- The rapid acceleration from 10% to 50% encounter data driving risk adjustment could depress risk scores. It's clear CMS is moving to 100% encounter data as quickly as possible and likely presages the use of encounters and not Fee-for-Service (FFS) claims to calculate risk factors as well as the phase-out of the coding intensity adjustment.
- CMS is proposing changes for Employer Group Waiver Plans (EGWPs) that amount to a "tax" on sponsors designed to reduce Medicare's spend on these 3 million of the 18 million beneficiaries in MA. EGWPs typically bid much higher than individual MA plans, and the proposal will likely result in a cost-shift to group members or a reduction in supplemental benefits. There was no estimated impact given, so watch this closely.
- CMS made it clear Star Ratings low performers will be executed by firing squad as early as next week. The Call Letter states plans rated below 3 stars for 3 consecutive years will be terminated in February 2016 for a December 31 effective date. Three to six plans qualify for termination. This will be the timeline for future years, and CMS states these decisions are non-negotiable.
- Huge news here on the compliance front:
- CMS notified Part D sponsors it's stepping up enforcement actions on coverage disputes and complaints, the leading noncompliance issue for plans.
- Plans failing the financial audits conducted on one-third of plans each year will no longer be subject to corrective action plans but rather sanctions and civil monetary penalties.
- CMS is ramping up audits and enforcement actions in network adequacy, provider directory accuracy, and medication therapy management programs.
As always, we now enter the frenzied public comment/lobbying phase where the industry tries to get an even better deal, with the final policies announced April 4. As these things go, MA plans should be generally happy about the financial picture while getting down to the busy work of getting the compliance house in order. Most of what's proposed here, we think, becomes the "new normal" long after Obama has left office.
Resources
Join John Gorman, GHG Executive Chairman, and colleagues, Olga Walther, Senior Legislative & Policy Advisor, and Leslie Mullins, GHG's Senior Consultant, as they provide a hard-hitting analysis of critical areas addressed in the document. Learn what the proposed "methodology changes" could mean for your organization and its partners, and the steps you can take to soften the impact on Tuesday, March 1 from 2:30-3:30 pm ET. Register now >>
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What to Watch: The Fiscal Year 2017 budget
President Obama released the Fiscal Year 2017 budget last Tuesday, which contains many significant proposals to government healthcare programs. Although both the Senate and House's budget committees already rejected hearings from the President's budget chief and unsurprisingly declared the bill "dead on arrival," the proposals do contain many bipartisan provisions with significant cost savings. One such proposal organizations should watch carefully, for example, is using competitive bidding in Medicare Advantage plans.
Most of the Medicare and Medicaid proposals are estimated to provide savings. The Congressional Budget Office's (CBO's) review of the budget in March will further shine light on which proposals will make it through the budget process. In a new memo, The GHG Policy team provides an overview of proposals to watch in a new memo, including:
ACA Updates
- Medicaid Expansion Incentive
- Uniform billing and out of network charges
- Marketplace eligibility determinations
- Cadillac Tax updates
Medicaid Budget Updates:
- Medical Loss Ratio (MLR)
- CHIP Funding
- Health Coverage Expansion Proposals
- Long-Term Services and Supports (LTSS)
Medicare Advantage (MA):
- Competitive Bidding Proposal
- Higher payments to high-quality MA plans
- Telehealth expansion
Part D:
- State-federal Medicaid negotiating tool
- Part D plan sponsor incentives to better manage high prescription drug costs.
- Increase of manufacturer rebates
- Mandate to provide rebates consistent with Medicaid rebate levels for drugs provided to low-income Part D beneficiaries.
Alternative Payment Models (APMs):
- Bundled Medicare payments for post-acute providers such as nursing homes and home health agencies.
- New bonus payment for hospitals that collaborate with certain APMs.
- Quality bonus program for the highest rated Part D plans
Resources
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10 Years of Star Ratings: Lessons Learned
The year 2016 marks the tenth year Medicare Advantage (MA) plan performance data has been collected for evaluation under the Centers for Medicare & Medicaid Services' (CMS') Star Ratings program. While we await the "new news" from CMS about new Star Ratings measures and other program updates in the impending Advance Notice, we thought it appropriate to celebrate this important milestone by looking at lessons learned through our first 10 years of Star Ratings and share some insights on how plans can leverage these lessons through the program's continued evolution.
Star Ratings, and the quality bonuses associated with strong Star Ratings performance, put MA plans squarely on a fast-track to rapidly improve MA beneficiaries' experience of healthcare (including quality, access, and reliability), to improve the health of the MA population, and to reduce or control the cost of healthcare within MA. As a result, MA plans have made tremendous investments of effort and resources over the past few years in the sprint to develop, deploy, and measure a whole host of tactics intended to achieve the all-important 4-Star Rating. The downside: these years of "trial and error" were often challenging, the work was often tiring for key personnel, and many plans built programs, reports, and tactics that may have worked well for yesterday's measures but which may not be ideally suited to support CMS' longer-term outcomes focus within the Star Ratings program. The upside: we now know, in great detail, the workflows, tactics, and population health strategies that efficiently and effectively support not only strong performance on quality measurement programs but also progress towards the Triple Aim.
During these last few days of calm before the annual Advance Notice and Call Letter season begins, here are a few strategic questions for your team to consider as you review CMS' proposed program updates during the coming weeks:
- Is your Star Ratings work plan achieving the level of success you desire?
- How will your Star Ratings work plan need to be updated to meet CMS' Star Ratings program updates? Are your 2016 tactics capturing the potential new measures under consideration by CMS?
- Which elements of your Star Ratings work plan are working well, and which need to be adjusted to achieve your goals?
- How are you leveraging the "basics" of Star Ratings such as care coordination, comprehensive diabetes care, medication adherence, and medication therapy management within your Medicaid, Accountable Care Organization (ACO), Marketplace, and Commercial populations?
- How effectively has your Star Ratings strategy improved outcomes and/or reduced costs?
- Do current workflows adequately address members' social and lifestyle needs (e.g., nutrition needs, stable housing, transportation, etc.)?
- How streamlined do your providers perceive your Star Ratings programs to be? How aligned are your Star Ratings programs with the many other quality programs in which your providers participate? How can your providers best support your quality needs?
Star Ratings success requires forward-looking precision to meet the needs of your members and your providers within the constraints of your budget while delivering strong performance in areas where your population or network under-performs the national average.
We understand success isn't easy, and evolution can be difficult. Whether you are looking to improve performance on just a few measures, need assistance interpreting the impending announcements in the Advance Notice, or are ready to more comprehensively evaluate your current Star Ratings program, we can help. For additional questions and inquiries about how Gorman Health Group can support your organization's Star Ratings programs, please contact me directly at msmith@ghgadvisors.com.
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Register your team now through February 14 for the 2016 GHG Forum, and take advantage of our standard registration rate of $1,095 before the price goes up to $1,295 on February 15. Register now >> For more details around the event and agenda, download the full conference brochure or visit our website.
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This Is the Year to Get It Right
Five consecutive years of very similar audit protocol, continuous partnering with sponsors to identify improvements, and numerous best practice/common conditions memos. Where are you in audit readiness? Did you evaluate the items in the 2016 Readiness Checklist sent in November? I will get back to that! In the meantime, the Centers for Medicare & Medicaid Services (CMS) has started sending audit letters, so we are aware of sponsors and Pharmacy Benefit Managers (PBMs) alike who are prioritizing CMS' requests. Early bird catches the worm, am I right? Presumably these plans have larger enrollment, since they will only be required to provide rejected claims for the one month of January.
Some priorities have not changed: Formulary Administration, Compliance Program Effectiveness, Organization Determinations, Coverage Determinations, Grievances and Appeals, and Model of Care activities are all still part of the base protocol. CMS has committed to releasing pilot protocol to review Medication Therapy Management (MTM) as well as Part C Provider Network Adequacy. Why this additional focus?
- CMS' focus on the reduction of opioid use may be one aspect of piloting the MTM protocol.
- The additional focus on Medicare Advantage (MA) networks is critical. In the past, there was not a requirement to evaluate providers to determine if they were open to new patients or not. If they were contracted and credentialed, then they were used for network adequacy. That does little good for a new member who cannot access that provider.
If you haven't done so, it is time to circle the wagons. CMS is managing a continuous cycle of new audits, audit report finalization, corrective action plan (CAP) review, and validation requests for a variety of sponsors. You cannot change past data, but you can put in place changes that could make improvements for you going forward. Nothing is more important (arguably) than ensuring your Compliance Program is strong. If you have a robust (and documented!) system for auditing and monitoring, you have a greater chance of finding shortfalls before CMS does. Earlier, I mentioned the 2016 Readiness Checklist, which was released on November 20, 2015. This is the sentence that keeps me up at night:
Should you identify areas where your organization needs assistance or is not/will not be in compliance, your organization must report those problems to your Account Manager directly by email in a timely manner.
While this could be viewed as a requirement to notify CMS upon checklist review (which should have been done prior to 1/1), a conservative interpretation would state that at any time, should you identify areas where the organization won't be in compliance, the organization must report to the Account Manager. If you look at it that way, then anything on that checklist pertinent to the program audit areas and identified as non-compliant in your audit period best be indicated as disclosed and not self-identified. Otherwise, CMS might ask why they didn't know about it prior. If you have not received an audit notice yet, do yourself a favor and evaluate your recent disclosures. The list you send to CMS will encompass items from January 1, 2016, through the start of the audit notice.
Resources
CMS audit practices have radically changed in recent years. Now with only days to prepare for CMS audits, organizations must become proactive in creating a culture of compliance. From a gap analysis to a comprehensive, deep-diving Part C and D audit, our team can help you minimize your compliance risk and maximize your time and resources. Visit our website to learn more >>
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Is Value-Based Insurance Design All It's Cracked Up To Be?
There continues to be a lot of buzz about value-based insurance design (VBID). VBID is the idea that consumers' out-of-pocket medical costs should be based on the value of a service to their health and not the price. Health Affairs defined VBID as "an approach that attempts to improve the quality of care by selectively encouraging or discouraging the use of specific healthcare services, based on their potential benefit to patients' health, relative to their cost."
Treatments, medications, and procedures evidence has shown to be effective and recommended for a condition are provided at no or low cost to the patient. Care that is ineffective or unnecessary is priced higher to discourage utilization. Corporations like Pitney Bowes, Caterpillar, and Marriott, and organizations like Oregon Educators Benefit Board and the Colorado Springs School District 11 have implemented several models of VBID. Reported outcomes include savings from reduced adverse events like hospitalizations and emergency department visits.
Some Medicare Advantage Special Needs Plans have designed their benefit structure along the lines of the value-based model. For example, members who have diabetes have $0 copays for necessary medications and may have additional benefits like gym classes, cooking classes, and Certified Diabetes Educator access.
Designing a value-based benefit for Medicare patients with chronic conditions begins with a review of the peer-reviewed treatment guidelines. These treatment guidelines can be accessed at https://www.guideline.gov/. Medications designated as first-line therapy should be provided at very low or $0 copays. Medications lower on the list, such as third- or fourth-line therapy, can be placed on a different/higher tier. Lab tests, provider visits, and other recommended therapies (physical therapy, exercise, dietary requirements, etc.) can also be provided at low cost to the member. Most chronic conditions lend themselves to a value-based design. Barriers like the cost of a custom formulary will hopefully be resolved by more industry uptake of VBID.
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Gorman Health Group can map the right strategy for realizing value-based care by aligning clinical and revenue cycle workflows for faster and more accurate payment, redesigning care delivery models to benefit from outcomes-based reimbursement, transforming the quality and effectiveness of care, as well as designing a value-based benefit for your members with chronic conditions. Visit our website to learn more >>
Register your team now through February 14 for the 2016 GHG Forum, and take advantage of our standard registration rate of $1,095 before the price goes up to $1,295 on February 15. Register now >> For more details around the event and agenda, download the full conference brochure or visit our website.
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Star Ratings Update: MedPAC Votes to Eliminate Double Bonuses
Star Ratings is already a hot topic in 2016, and we're only one month into the new year. In most recent news, the Medicare Payment Advisory Commission (MedPAC) unanimously voted last month to eliminate the double bonuses associated with Star Ratings, while also virtually unanimously voting to exclude diagnoses collected during in-home assessments from the Medicare Advantage Risk Adjustment model. Although the Centers for Medicare & Medicaid Services (CMS) may opt to take an alternate approach to resolve Risk Adjustment issues within Medicare Advantage, and since CMS can't independently remove double bonuses with amending certain elements of the ACA legislation, this new development is a great reminder of the need to periodically pause and evaluate the value and ROI of programs which remain prominently placed on CMS' radar screen.
When CMS continued their support of in-home assessments in the 2016 Call Letter, we all breathed a collective sigh of relief. And since that announcement, we have seen significant effort by both health plans and vendors to make these assessments even more clinically and socially focused while simultaneously aligning them with Star Ratings measure needs. As a result, any strategic changes made in response to MedPAC's January votes could have a pervasive impact on the care models and operational structure health plans have come to rely on for Star Ratings success. CMS' response to MedPAC's recommendations, along with the plethora of other potential Star Ratings program updates may not only impact health plans and providers, but could also impact a wide array of health services purchased through vendors.
Many health plans (and their vendors) have leveraged risk assessment work streams to hardwire carefully-planned and strategically-prioritized clinical care and care planning activities into in-home assessment workflows in order to seamlessly impact Star Ratings and achieve multi-faceted return on investment (ROI). In addition, the data collected during risk assessments is often stored in centralized data warehouses and used throughout the health plan as a foundation for population health, care management, and consumer experience strategies. And if that wasn't enough, because members often value the relationship with, and advice received from, the clinician they allow into their home, any changes to in-home assessments introduce a host of new risks relative to self-care and disease management, member satisfaction, and consumer experience.
As we await guidance from CMS regarding their response to MedPAC's recommendations and regardless of how CMS ultimately responds to both issues, this is a great time for leadership to study and thoughtfully consider a number of decisions which could result from either the elimination of double bonuses or changes to CMS' treatment of in-home risk assessments:
- What is the downstream Star Ratings impact of any benefits proposed for reduction or elimination?
- How have quality, medical management, pharmacy, Star Ratings measure gap closure, member retention, and other strategic priorities been hardwired into in-home risk assessments?
- What is the secondary ROI from in-home risk assessments on Star Ratings measures, health outcomes, medical loss ratio (MLR), member satisfaction, and member retention?
- Are current work streams adequate to support strong 2016 performance on new Star Ratings measures under consideration for addition to the Star Ratings program?
- How is each department using the data collected during in-home risk assessments?
- How well positioned is the provider network to serve the care planning and care management needs of members currently receiving in-home assessments?
- What types of alternative workflows and tactics will be used in the event diagnoses obtained from in-home assessments are not allowed for risk adjustment purposes?
Because time is of the essence in our industry, strategic planning and change management never ends. As John Gorman has said for years, it will be the most adaptable plans which will both survive and thrive through the tumultuous industry evolution.
In-depth analysis and industry-leading commentary on the key announcements from CMS and MedPAC can be found in this recently created white paper.
Gorman Health Group (GHG) can help you adapt your Star Ratings approach to account for these potential changes and streamline your Star Ratings strategy to influence health outcomes while remaining compliant with CMS regulations. For additional questions and inquiries about how GHG can support your organization's Star Ratings programs, please contact me directly at msmith@ghgadvisors.com.
Resources
Register your team now through February 14 for the 2016 GHG Forum, and take advantage of our standard registration rate of $1,095 before the price goes up to $1,295 on February 15. Register now >> For more details around the event and agenda, download the full conference brochure or visit our website.
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Breaking the Incompatibility Barrier — Four Keys to Merging Operational Productivity and Compliance
Can compliance and efficiency co-exist in Operations? Is there a "right" balance between the two, or could it be more of an intertwining of the two? If you have been in Operations long enough, you have been told you have to increase efficiency, reduce staff, and improve handle time or auto-adjudication rates. What you probably have not been told is to be more compliant, except maybe by the Compliance Department. Widgets in, widgets out, is the name of the game.
It's a lot of plates to keep in the air, trying to balance more with less, and now we add in compliance. What if compliance and productivity cannot only co-exist but can cause a department to thrive? Here are the four critical keys to an intertwined compliant, productive Operations team.
- Don't Ignore the Human Factor — Productivity and compliance are both reliant on employees. All the best tools, reporting, and systems can be in place, but if well-trained and engaged employees aren't on the team, we won't have well-run productive and compliant processes and teams. Employee engagement, like member engagement, is critical to success.
- Know the "Why" behind an Action — We need to change compliance from an obstacle to be circumvented to a process to be embraced. We do that by showing the relevance to the process — the "Why." Have you asked your team what the critical Centers for Medicare & Medicaid Services (CMS) requirements are for the activities they perform? Does the Claims staff know the time frames for processing a claim or the requirement for a clear and understandable denial reason? Even more important, do they know why those requirements are in place and how they impact the beneficiary?
- Have the Right Tools — Do you know how many manual work-arounds your team completes on a given day? How many member communications must be manually completed? How much manual research is needed to adjudicate a claim? Does your management know? IT changes are costly and take time, but we must get things on "the list." That's why a current prioritized list of enhancements is needed. Make sure to document the productivity and compliance loss due to the work-arounds. Include team member's input — their voice is important to understanding the true issues. Spearhead the top critical needs on the earliest IT release possible.
- Provide Measurable Results of Success and Failure — How do you and your teams know when you are successful or when you failed? Do your reports show both your production and compliance goals? Typically, Operations has lots of reports, but how are they aligned — with commercial or Medicaid metrics or the unique Medicare metrics? Is this shared with your team?
In the Medicare world, Operations can't be a balancing act — it's all about intertwined compliance and productive Operations teams. At Gorman Health Group, we know how important it is to link compliance and productivity. For actionable advice on this topic and best practices, join us at our annual Gorman Health Group 2016 Forum, April 19-20, at the Worthington Renaissance Fort Worth Hotel in Fort Worth, Texas.
During this year's information-packed two days, our elite team of experts, operators, clients, and partners will help you figure out what matters and what doesn't. We will share proven tactics to cut costs, increase member satisfaction, and manage and drive sustainable growth. Register now >>
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Register your team now through February 14 for the 2016 GHG Forum, and take advantage of our standard registration rate of $1,095 before the price goes up to $1,295 on February 15. Register now >> For more details around the event and agenda, download the full conference brochure or visit our website.
Stay connected to industry news and gain perspective on how to navigate the latest issues through GHG's weekly newsletter. Subscribe >>
Risk Adjustment: Proposed Changes & New Regulations
At Gorman Health Group (GHG), we pride ourselves on having our fingers on the pulse of what continues to be a complex and volatile government programs environment. Whether it is fact or fiction, our clients and our peers look to us to interpret and filter through the official announcements, the breaking news, the propaganda, and the hype.
Being accountable for GHG's Risk Adjustment division keeps me and our team of consultants quite busy, and just when other departments get to breathe for the holidays, we are inevitably fielding questions and providing "home stretch" support to clients as they prepare for the final submission of risk adjustment data. (In case you missed it, CMS published this memo outlining extended deadlines for data submission.) See full memo here.
If you live in the risk adjustment world, you know this critical business function never really takes a holiday. The Centers Medicare & Medicaid Services (CMS) calendar for data collection and submissions leaves little room for vacations, especially knowing risk scores recalibrate annually and the work to ensure complete and accurate diagnostic data for Medicare Advantage (MA) beneficiaries requires a watchful eye at all times. The reality is, either your hair is on fire, or you just sent the guy in the cube next to you out to refill your propane tank.
Whether we are in the trenches with our clients, or supporting them from afar, GHG is always keeping an eye on what is coming next. So, while you were collecting charts and checking them twice, and making sure your In-Home Assessment vendors were sending information to your Case Management department, here is what has been coming across the wire…don't worry, we have been keeping tabs on all of the critical activity in the risk adjustment space:
October 28, 2015: CMS announces proposed changes to the CMS-HCC Risk Adjustment Model for Payment Year 2017 which would apply "improved predictive ratios" for full benefit and partial benefit dual-eligible beneficiaries.
November 4, 2015: CMS admits to having underpaid dual-eligible health plans and, in turn, overpays for beneficiaries with low medical costs, sparking concern not only about inequities in payment, but the potential for adverse selection.
December 2, 2015: CMS released an early preview of 2017 MA Ratebook Growth Rates, signaling a hopeful bump in MA plan payments due to a 3.1% increase in traditional Medicare spending in 2017. This is one variable in the equation. Risk adjustment calculation changes and other policy changes will complete the puzzle. More to come on February 22 when CMS releases the Advance Notice for 2017. Stay tuned.
http://www.modernhealthcare.com/article/20151202/NEWS/312029999
December 28: CMS released a Request for Information outlining the expansion of Medicare's Recovery Audit Program in an effort to identify instances where Medicare is overpaying.
http://www.modernhealthcare.com/article/20151228/NEWS/151229937
January 14, 2016: The Medicare Payment Advisory Commission (MedPAC) voted to pass recommendations which would change how MA plans are potentially paid, potentially saving CMS $5 billion and revealing its position on In-Home Assessments and Star Ratings Quality Bonus Payments.
http://www.modernhealthcare.com/article/20160114/NEWS/160119925
January 22, 2016: This one has a bit of a political spin to it, but we thought it was worth reporting. AHIP released a funded analysis conducted by Avalere Health, finding the risk adjustment model used by CMS "lowballs" the cost of treating chronic conditions such as depression, osteoarthritis, chronic pain, and rheumatoid arthritis by millions, and, in some cases, billions of dollars.
http://www.modernhealthcare.com/article/20160122/NEWS/160129948
Just like our consulting services and our analytics solutions, we assessed the current state of the Medicare risk adjustment industry, collected our findings, and delivered meaningful, actionable information which will keep our clients and readers informed and prepared for what lies ahead in 2017.
A more in-depth analysis and industry-leading commentary on the key announcements from CMS and MedPAC can be found in this recently created whitepaper.
For additional questions and inquiries about how GHG can support your organization's risk adjustment programs, please contact me directly at dweinrieb@ghgadvisors.com.
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Whether you rely on multiple vendors or a largely internal team, GHG can help you streamline the execution of your risk adjustment approach, and build a roadmap to ensure you're keeping pace with CMS expectations in both compliance and health care outcomes. Visit our website to learn more >>
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Sales 2017 Readiness — Are You Maximizing Your Sales Potential Today?
Here we go again, planning for the upcoming selling season. Every year it seems to approach more quickly than the year before. Are you ready? If the answer is no, or you are not sure, here are a few critical items to consider as you create your 2017 Annual Election Period (AEP) strategy:
- Market Analysis — What worked during AEP 2016? This is the time to reflect on strategies which helped and/or hindered your success from the previous year. While it's fresh in your mind, create a market analysis to review all the components of your sales process. From material distribution to product design, it's important to understand what components of your strategy worked and what needs to be adjusted.
- Channel Mix — Do you have the right mix of agents to represent your plan? It's important to evaluate the effectiveness of both your internal and external sales forces. The industry is moving toward a more diverse distribution channel. The need for internal and external field agents, coupled with telesales, helps maximize your footprint and reach all corners of your market.
- Seminar Plan Development — Did the materials you provided keep your agents compliant during their presentations? CMS secret shoppers are out in full force, and having the right tools for your agents will be imperative to high Star Ratings. In addition, baby boomers are also forcing us to rethink how we present products to Medicare beneficiaries. With the growth of internet shopping, online enrollment presentation opportunities must be included as a part of your strategy.
- Marketing — Did your direct mail make the phones ring, or did your marketing miss the mark? How you implement your marketing strategy impacts lead flow, brand awareness, and enrollment. Successful marketing programs deploy a multi-touch communication strategy which blends education, lead generation, and conversation tactics to maximize new member acquisition.
- Sales Training — Was your sales force ready to sell your plan? Sales training is a critical part of plan and agent success. Create a curriculum which encompasses sales and product training, time management, Medicare basics, and compliance. Don't forget to teach them about member retention―it's hard enough to acquire new members, so you also need to know how to retain them. Enable your agents to start the season with all the knowledge needed to make that sale and keep that new member on the books.
With the narrowed time frame for AEP, your sales strategy must continually change to adjust to the Medicare climate. What worked last year may not work this year. Don't delay, the time is now―start planning for your success today!
For more information, please contact Carrie Barker-Settles at cbarkersettles@ghgadvisors.com.
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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 >>
Register your team now through January 31 for the 2016 GHG Forum, and take advantage of our New Year's special! Save 15% using promo code NewYear16 at checkout. Register now >>
Stay connected to industry news and gain perspective on how to navigate the latest issues through GHG's weekly newsletter. Subscribe >>
To File or Not To File, That Is the Question
We've made it clear through this blog the Centers for Medicare & Medicaid Services (CMS) is throwing down the gauntlet in terms of ensuring Medicare Advantage provider networks are adequate. The biggest change to the 2017 application process supports this initiative. For Service Area Expansions, CMS is requiring current service area network data at the contract level in addition to the pending service area data. Previously, CMS requested only those providers supporting the pending counties. Applicants took to the CMS User Calls to ask clarifying questions about this requirement, including a number of "what if" questions, indicating that applicants either know they have unknowns in their networks, or they know how their network fares and they want to know the consequences. In addition to some provider network documentation changes, here are some other notable changes to the application process:
- Quality Improvement Plan and Crosswalk are no longer required at the time of submission.
- If a contract of the applicant has been terminated or non-renewed over the past two years, a Two-Year Prohibition Waiver Request is required.
- Additional required contacts have been added.
Here are some key dates to keep in mind:
- User Calls took place on January 13 and 20. Current and pending Sponsor applicants are encouraged to review the CMS Part C & D User Call recordings.
- The application deadline is February 17, 2016, at 8:00 PM Eastern time.
- Part C deficiency notices will be sent mid-March.
- Part D deficiency notices will be sent late March.
- Part C and Part D Notices of Intent to Deny or Approve will be sent late April.
- Requests to drop counties are due May 20.
- Part C and Part D Conditional Approvals or Denials will be sent late May.
Additional important dates have been communicated in the Part C and Part D application materials and in the User Call presentations. Something CMS has made clear again this year is that applicants should review all instructions provided, and reach out with questions, as there are no exceptions to the filing deadline. A well-prepared applicant will target for an early submission date so as not to risk getting caught up in a bottleneck of uploads. If you haven't done so already, get ready and start your engines!
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