Integrated OTC Benefits: A Prescription for Customer Satisfaction
Most over-the-counter products and medications like pain relievers, allergy medications, heartburn drugs and topical antimicrobials were once available only by prescription. In OTC form, these drugs are FDA approved and often equally effective as prescription drugs at a fraction of the cost. Yet their OTC status has long meant these drugs are not covered under prescription drug plans for Medicare Advantage, Medicaid or commercial health plans. As a result, consumers with limited incomes may simply forgo needed medications while others may opt for more expensive prescription drugs that are covered by their health plans.
Adding an OTC benefit component to a health or drug plan may seem like one more administrative burden. After all, why add products and medicines to a formulary that subscribers are already buying anyway? Because an integrated OTC benefit can be a real cost-saver for health plans and subscribers alike, and OTC benefits boost customer satisfaction and retention.
The Consumer Healthcare Products Association Clinical/Medical Committee found that OTC medicines bridge treatment gaps, are convenient and reduce unnecessary use of health care services. The Center for Medicare and Medicaid Services allows OTC coverage in Medicare Part D drug plans in acknowledgement of OTCs’ utility as part of step-therapy algorithms and to improve cost-effective utilization management.
Each dollar spent on OTC medicines saves the US health care system $6 to $7, according to a 2012 study commissioned by the CHPA. The savings come not only from lower drug costs but also from fewer patient visits to health care providers and emergency departments.
The key to an effective OTC benefit is seamless integration of robust formulary management, benefit management and customer service. Various vendors offer an OTC benefit add-on in the form of prepaid cards, but the cards must be set up to cover only approved drugs. The result is frustrated customers who find out at the pharmacy cash register that their card doesn’t cover the medicines and health supplies in their shopping carts. That’s not good for customer retention.
What Carriers Should Look for in an OTC Benefit Partner
An effective OTC benefit partner relieves administrative burdens on the carrier by managing formularies, handling member interactions, processing eligibility files frequently and generating required reports accurately and promptly. Added features like developing and distributing online and print catalogs to subscribers and mail-service delivery of approved OTC medications and supplies further enhance customer satisfaction. Mail service also enables the inclusion of educational, program and informational inserts in OTC product shipments.
An OTC plan partner should also be experienced and well-versed in compliance with regulatory requirements and oversight for OTC benefits, and the partner must be able to assist with development of a formulary that meets the carrier’s goals. In addition, all technology used for OTC benefit administration must be able to demonstrate adherence to the latest security standards for robust cybersecurity and privacy protections.
A Turnkey Solution
A fully functional OTC program delivered with minimal effort from the carrier, full CMS compliance and quality assurance, and robust cybersecurity and privacy protections relieves the administrative burden on carriers. Packaged with exceptional member service and convenience, such a program constitutes a turnkey solution that contributes to plan STAR, HEDIS and NPS ratings, while delivering customer satisfaction, retention and market share.
Convey Health Solutions focuses on building specific technologies and services that can uniquely meet the needs of government-sponsored health plans. Convey provides member management solutions for the rapidly changing health care world.
Learn more about Convey’s OTC Benefit solution here.
For information on the other solutions Convey has to offer, please follow this link.
Resources:
"Plans that offered an OTC benefit in 2018 won big during AEP," explained GHG leaders during a recent webinar. Download the recording now.
Registration is open for the Gorman Health Group 2018 Forum, April 25-26, 2018, at the Red Rock Resort ideally located near the Red Rock Canyon in Las Vegas. Download our agenda here.
Stay connected to industry news and gain perspective on how to navigate the latest issues through GHG’s weekly newsletter. Subscribe
Three Considerations For Those Entering Medicare Advantage
Every few months the industry hears news of new players getting into the Medicare Advantage (MA) game. And why not? According to the Kaiser Family Foundation, more than 19 million Medicare beneficiaries are enrolled in MA plans this year. Either someone is building from the ground up or purchasing an existing structure, such as CVS Health Corporation’s recent agreement to acquire Aetna. I don’t expect this will be the last pharmacy benefit manager to look for an insurer partner with the promise of being able to lower healthcare costs. While analysts argue over the benefits and concerns, one thing is for certain: you need experienced administrators at the helm. I borrow from the late Mitch Hedberg who summarized just because you can do something really well in one field doesn’t make you an expert in everything:
Whether you are building from scratch or partnering with an established entity, you might be adept at one thing but not necessarily everything related to it, nor should you be. In Hedbergian spirit, I’ve outlined three pieces of advice for those entering this arena.
- If preparing for the Part C and Part D Application process, the clock is ticking. Make sure the right people are in place to implement this product. If the application submission is the wedding day, the implementation and execution are the marriage. What vendors are being considered vs. what will be built in-house?
- For those undergoing mergers, I speak from experience about its arduous process. Integration activities do not happen overnight, nor should they, but it is possible the drivers of success may get derailed during integration. Thoughtful engagement of the right people with the experience and skillset in the delivery of this product is imperative to make sure successful practices are not lost.
- Focus on what needs to be done in order to be successful, but first, make sure everyone agrees on the definition of success. Is it fiscal success for long-term viability? Is it the establishment of a sustainable product set with steady membership growth? Are Star Ratings and other quality measures part of the equation? We always hear about top-down communication strategy, but for those responsible for implementation, lateral communication is essential. Ensure everyone understands the organization’s priorities, and remove silos that impede progress.
- Know your members well. What does the market look like? What are their health and cultural needs? What are the product, benefit, and premium trends in the area? If you are submitting an application, you have likely already gone through these studies as outlined recently by my colleague Diane Hollie in a recent article on expansion strategy.
You do not want to set up your organization or team to fail – no one sets out that way. Before you apply for the first time, expand, or acquire an existing plan, establish the right team, be on the same page, and understand your market. If you need assistance, please contact me directly at rpennypacker@ghgadvisors.com.
Resources:
Registration is now open for the Gorman Health Group 2018 Forum, April 25-26, 2018, at the Red Rock Resort ideally located near the Red Rock Canyon in Las Vegas.
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 >>
Stay connected to industry news and gain perspective on how to navigate the latest issues through GHG’s weekly newsletter. Subscribe >>
Pressure Test your 2019 Expansion Strategy in 3 Steps
Do it now! Get your benefit strawman, enrollment projections, and financial goals developed before benefit season begins!
Step 1: Market Analysis – Hopefully you have already performed this step before you submitted the Notice of Intent to Apply (NOIA), but if not, it’s not too late. A market analysis typically includes the following:
- Penetration analysis
- Enrollment trends and market share
- Product trends and growth patterns
- Competitive analysis
- Premium and benefit trends
- Demographic analysis
Now that the 2018 benefits have been released, it is time to relook at the product, benefit, and premium trends through a market analysis to see what has changed so you are fully prepared for the beginning of benefit season in February 2018. The Gorman Health Group (GHG) Marketing team was just evaluating a new product for a client and discovered their competitors added three new plans for 2018. This changes how you look at the market. It is important to understand how your clients changed their product and plan portfolio for 2018 and then look at the 2018 Annual Election Period (AEP) results in February to solidify your market analysis, but you will want to start building your strawman of benefits and premiums now.
Step 2: Market and Enrollment Opportunity – Understanding your market opportunity is critical, and too many times a Medicare Advantage (MA) plan develops enrollment projections on the back of an envelope or in a board meeting instead of looking at the market and understanding the “real” market opportunity. Understanding the market potential and then looking at how much of the market you will be able to gain is a much better way to estimate your enrollment projections.
Our Product team recently worked with a client who was trying to determine why there was such a variance between their current sales results and enrollment projections. During GHG’s review of the client’s enrollment projection methodology, GHG identified certain demographic and market considerations were not included despite being taken into consideration when developing their marketing and sales strategies.
“These exclusions [demographic and market] are common,” says Nilsa Rudisill, Vice President, Sales, Marketing & Strategy, “and even more so is disconnect between company enrollment projections and sales and marketing strategies.”
Step 3: Financial Feasibility Study – The next step is to pressure test your hypothesis with a financial feasibility study. Although a feasibility study is not an actuarial study, it does test whether a hypothetical benefit design could work in a target market based on revenue and cost characteristics of that market. It also takes into account assumptions about the Centers for Medicare & Medicaid Services (CMS) payment trends, enrollment, premium and costs, and projected enrollment over a period of five years.
GHG’s Finance, Marketing, Sales and Product teams work very closely together to customize the assumptions that impact this study for our clients based on level of comfort, capabilities, and growth opportunity, even if it means the overall opportunity does not look promising in the end. For example, this study was performed for a client who was interested in offering a Special Needs Plan statewide. Although the financials appeared sound, we looked beyond the numbers to tell the client “what it really” takes to launch a successful product in their particular market by providing multiple financial scenarios, including a scenario that appeared less profitable in the short term but actually more manageable as a company new to MA.
This process allows you to make smart, informed decisions about your current or potential market without all the investment upfront. This type of process is not a one and done! It tends to be a very iterative process to understand how to dial the levers in the market to see if and when you can expect profitable growth. So take the time now to get it done right, or spend the money later by guessing incorrectly.
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 >>
Stay connected to industry news and gain perspective on how to navigate the latest issues through GHG’s weekly newsletter. Subscribe >>
CMS Notice of Intent to Apply
The Centers for Medicare & Medicaid Services (CMS) Annual Call Letter calendar marks November 13, 2017, as the first due date for the Notice of Intent to Apply. It is expected the Center for Medicare will release a reminder memo this month outlining the details. In general, the agency requires a Notice of Intent to Apply to be submitted when an organization plans on submitting a request for any of the following:
- Offering a new product type (such as a Medicare Advantage Prescription Drug plan or Prescription Drug Plan)
- Transitioning an existing non- or partial network Private Fee-for-Service (PFFS) to a full network PFFS
- Expanding the service area of an existing contract
- Expanding only an employer-only service area
- Adding prescription drug benefits to an existing contract for the first time
- Adding Employer Group Waiver Plan (EGWP) market to an existing individual-only service area for the first time
- Adding individual market to an existing EGWP-only service area for the first time
- Adding or expanding the service area of a Special Needs Plan
- Expanding the service area of an existing Medicare-Medicaid Plan
While organizations will have another opportunity once the final application guidance is released in January, for the most part, those who have properly planned are generally certain by November if they intend to pursue this initiative. Feasibility discussions have occurred to help leadership make that “go/no-go” decision. “Along with feasibility discussions, network analysis to determine adequacy and potential gaps is a critical component to consider as you decide on submitting your Notice of Intent to Apply,” states a colleague on the Operational Performance team. “Those steps will help set up the plan to move forward with their application filing.”
Turning to the application, interested parties have certainly already gone through the draft Part C and Part D applications with a fine-tooth comb to determine what’s new for the coming submission and what isn’t needed. If you haven’t reviewed the documents by now, what’s changed may surprise you.
The Notice of Intent to Apply is due in about a month. If you’ve conducted a feasibility study but are still unsure of what to do, don’t be alarmed. (Well, ok, be a little alarmed, but take a step in the right direction and contact us.) Then, once you have made the decision to pursue an application, ask us for assistance. Gorman Health Group has a proven track record of successful application assistance and support. Going in with a clear understanding of the process and expectations helps you put your organization’s best foot forward in the pursuit of this new endeavor.
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 >>
Stay connected to industry news and gain perspective on how to navigate the latest issues through GHG’s weekly newsletter. Subscribe >>
Now Is The Time To Start Planning For 2019 Medicare Advantage Growth
Here are three planning questions you need to ask yourself right now:
- Are you losing market share because you are not offering the right products or product mix?
- How could the profitability of your Medicare Advantage (MA) enrollment change if you expanded your service area?
- Is now the time to begin offering an MA plan?
There is a proven process to go about answering these questions.
The first step begins with a market analysis to assess both current and/or proposed markets. Looking at market enrollment trends and understanding the market demographics with product and premium analyses help you understand what levers are driving the market. Plus, a benefit analysis starts to show which benefits at which premium price points are most favorable.
You then want to take the results from the market assessment and build an enrollment projection to understand what the five-year trend might be with a new product at a certain benefit level and price point or how your current product might perform in a new service area.
The next step is to pressure-test your hypothesis with a financial feasibility study. Although a feasibility study is not an actuarial study, it tests whether a hypothetical benefit design could work in a target market based on the revenue and cost characteristics of that market. It also takes into account assumptions about the Centers for Medicare & Medicaid Services (CMS) payment trends, enrollment, premium, and costs.
This process allows you to make smart, informed decisions about your current or potential market without all the investment upfront. Now is the time to start planning since the Notice of Intent to Apply (NOIA) is right around the corner in November. This type of process is not a one and done! It tends to be a very iterative process to understand how to dial the levers in the market to see if you can develop additional, profitable growth. So take the time now to get it done right, or spend the money later by guessing incorrectly.
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 >>
Stay connected to industry news and gain perspective on how to navigate the latest issues through GHG’s weekly newsletter. Subscribe >>
Addressing Key Questions on the 2018 Medicare Marketing Guidelines
We had a fantastic turnout for our webinar last week on the 2018 Medicare Marketing Guidelines (MMG). Something I’ll reiterate is that the MMG are for everyone. Nilsa Rudisill and I had plenty of spirited discussions when working to narrow down the content to fit in a single hour. We know your time is valuable, and we appreciate everyone’s attendance.
Some great questions were received that Nilsa and I thought would be beneficial to share in case others in the industry are contemplating similar themes. Some of our clients even shared their responses from the Centers for Medicare & Medicaid Services (CMS). While we cannot share those specific responses, it does confirm to us there are ambiguities in certain sections, and the agency is responding in a timely manner. Therefore, if you are in doubt, reach out!
- Let’s address the sample Summary of Benefits (SB), a key document for beneficiaries. By no means is the sample a “model” document in the same vein as CMS releases model Evidence of Coverage documents. Most readers already have their SBs under development, which is great.
- A few questions came in pertinent to the submission of events to CMS in the Health Plan Management System (HPMS). When does the change take place? The guidance applies to 2018 activities. Unless CMS says otherwise, continue to submit events pertinent to the 2017 plan year.
- Does the change in HPMS submission of events signal a change in surveillance activities? From the outside looking in, the answer is yes. CMS used the information submitted by sponsors to select events for surveillance. A change in the agency’s direct monitoring activities should not change your own internal monitoring and auditing, unless, that is, you already know you need to step it up.
- How should Scopes of Appointment (SOAs) now be tracked? Nothing much has changed. The documentation may be in writing in the form of a signed agreement by the beneficiary or a recorded oral agreement. Any technology (e.g., conference calls, fax machines, designated recording line, pre-paid envelopes, and email) can be used to document the SOA. Remember, you must document the scope of the appointment prior to the appointment. Be prepared to demonstrate this in your documentation.
As we’ve stated before, you’ve got to wonder if each revised chapter CMS issues is a collection of lessons learned from the previous period of time. Regardless, the agency seems to be streamlining and refining guidance not only to ease burden on sponsors but to also provide necessary clarification as needed. What changes are impacting your organization and to what extent? Contact us on ways we can help your operations be successful in implementing the MMG.
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 >>
Stay connected to industry news and gain perspective on how to navigate the latest issues through GHG’s weekly newsletter. Subscribe >>
Three Reasons Why Pre-AEP Marketing Is Critical
One of the reasons healthcare marketing is so interesting is that it’s never static for long. Once you think you have it figured out, something changes in the mix. Pre-Annual Election Period (AEP) marketing is one of those phenomena that changes the mix in AEP marketing. If a pre-AEP marketing strategy is not in your marketing plan this year, here are three reasons why you may want to reconsider:
- In working with plans across the country, many are finding the pre-AEP mailing to be the most cost-effective mailing in the AEP mix and also generates the most leads. Typically, these are inexpensive mailings or postcards that arrive in the mailbox the latter part of September – right before AEP.
- Since the Centers for Medicare & Medicaid Services (CMS) states plans/Part D sponsors cannot market for an upcoming plan year prior to October 1, you must develop advertising that is very generic in your messaging, can be informational and educational, and utilizes direct response-oriented language with a very strong call to action to generate a response. This strategy seems to be paying off.
- When a plan is new to the market or introducing a new product to the market, multi-channel, pre-AEP marketing has been found to be very productive. Advertising the brand and/or hinting of something new helps build recognition, chatter, and leads before the full barrage of marketing begins in October, especially for new plans. Although this type of marketing may not have a strong return on investment by itself, it can be measured in the overall AEP marketing analytics.
Whatever your situation, we have seen pre-AEP marketing take many different approaches – with a few that appear to have crossed the line – so make sure you “stay within the lines” of CMS’ regulations with your pre-AEP marketing. We would be happy to assist you with developing a pre-AEP strategy to help you meet your goals.
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 >>
Stay connected to industry news and gain perspective on how to navigate the latest issues through GHG’s weekly newsletter. Subscribe >>
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 >>
Stay connected to industry news and gain perspective on how to navigate the latest issues through GHG’s weekly newsletter. Subscribe >>
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 >>
Tips for a Multicultural Marketing Strategy
We are all familiar with the 5% language threshold requirement by which the Centers for Medicare & Medicaid Services (CMS) mandates Medicare Advantage Organizations (MAOs) to make specific marketing materials available in any language that is the primary language of at least 5% of an MAO’s service area. This is the bare minimum. With 8% of the nationwide 65-and-older population being Hispanic or Latino, 8% being black or African-American alone, and 4% being Asian alone, it is important for MAOs to identify the various race and ethnic footprints in their service area and to distinguish multicultural marketing and advertising tactics throughout strategy development. Language is only a piece of the story – understanding variations in culture is key to building a successful and ultimately profitable relationship with potential and current members.
MAOs’ sales and marketing strategies must consider multicultural tactics. Here are four key areas to focus on when developing these tactics:
1. Start with the data. MAOs must always start by knowing their market, both prospective and current membership. To meet this necessary step, a thorough analysis of census data and current membership data should be prepared. If you utilize a marketing agency, this is an opportunity to work with them as they may have market data that goes above and beyond census data that is specific to your service area. The information gained at this step should be refreshed at least annually and serves as the base upon which you will build out the multicultural strategies – without the data, there would be no direction.
2. Represent your population within your sales and customer service teams. If you find you are servicing a multi-cultural/ethnic population, it is absolutely critical to have all ethnic groups represented in your Sales and Customer Service teams. For many ethnic groups, the sales agent/broker is considered an individual’s customer service representative, and they may look to their agent/broker as their trusted partner even before the health plan. To be successful in a multicultural environment, your Sales team must be a familiar face and have a strong presence in the community. In addition, MAOs should not hesitate to work with their Field Marketing Organizations (FMOs) to ensure ethnic agents are in the right locations and to conduct focus groups with brokers to understand how the plan benefits and the MAO overall are resonating with the various cultures represented.
3. It’s not just about the language. Materials should go above and beyond the 5% threshold rule. Important things to consider in developing multicultural materials are:
a. Colloquial versus formal language
b. Gender sensitivity across different cultures
c. Multiracial/multicultural pictures on advertisements
d. Deliver brand message with social opportunities
e. Mobile tools
Infrastructure is critical when targeting and servicing ethnic populations. It is important to have representation of the various cultures on your team. This is an opportunity to test translations internally. Gorman Health Group (GHG) also recommends performing focus groups with your current membership to test translations and things like gender sensitivity across cultures. In addition, understand what each of your ethnic populations responds to from a marketing perspective. Are there marketing tactics or channels that work better? Or do you need to find them in your grass roots campaigns?
4. Network Development. Serving multicultural populations is an opportunity for Marketing to work with Network Development to ensure staff within these areas are aware of the languages and cultures represented within the service area. This information should help guide recruitment efforts, especially for Primary Care Providers (PCPs). And once a provider is part of your network, Marketing may work with the provider to send direct mail pieces to specific current members promoting the provider in the language and culture that provider represents. In addition, the MAO should work with their providers to develop strategies that will enable them to deliver effective healthcare services that meet the social, cultural, and linguistic needs of members.
The archetypal health plan does not typically resonate with small ethnic groups. If you find you are servicing a population that is multicultural, it is important to align yourself with these groups and build unique relationships. All cultures in your service area should be considered in product development, marketing and sales strategies, network development, and customer service representation. Don’t miss out on potential members or lose current members by ignoring ethnic groups and their value in your service area. As the Medicare Advantage market becomes more homogenized and saturated, growth will need to come from other sources – don’t wait until your competition has already figured it out.
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 >>
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