With the Centers for Medicare and Medicaid Services’ (CMS) recent release of the 2021 chapter 2 enrollment changes, Medicare Advantage (MA) plans now have insight into the many proposals made earlier this year. GHG’s Vice President of Sales, Marketing & Strategy, Diane Hollie, summarizes the key changes.

Medicare Advantage Plan Options for End-Stage Renal Disease (ESRD) Beneficiaries

Effective January 1, 2021, ESRD Medicare beneficiaries will now be able to enroll in MA Plans. Previously, ESRD patients could only enroll in a Medicare Supplement plan, MA Prescription Drug plan, or Medicare only.  This upcoming Annual Enrollment Period (AEP) is the first time ESRD beneficiaries can enroll in an MA Plan, even after diagnosis. Although this is a major change, plans have known about this for several years.  

Special Election Periods (SEPs) for Exceptional Conditions

In addition to codifying SEPs previously adopted and implemented, CMS established two new SEPs for exceptional circumstances:

• SEP for Individuals Enrolled in a Plan Placed in Receivership. 
  • CMS established new SEPs for members enrolled in plans that are experiencing financial difficulties to such an extent that a state or territorial regulatory authority has placed the organization in receivership. 
  • The SEP begins the month the receivership is effective and continues until it is no longer in effect, or until the enrollee makes an election. The MA plan must notify its members, in the form and manner directed by CMS, of the enrollees’ eligibility for this SEP and how to use the SEP.

• SEP for Individuals Enrolled in a Plan that has been identified by CMS as a Consistent Poor Performer. 
  • CMS established new SEPs, for individuals who are enrolled in plans identified with the low performing icon (LPI). This SEP exists while the individual is enrolled in the low performing MA plan.

Medicare Advantage and Prescription Drug Plan Model Enrollment Forms

CMS revised and improved the standard model form used for MA and Prescription Drug Plan (PDP) enrollment into a new streamlined form. The new model enrollment form requires a minimal amount of information in order to process the enrollment, and other limited information that the MA Plan is required or chooses to provide to the prospective member.

The new model form consists of the following parts:

• Cover Page – The cover page includes information for the prospective member on Medicare enrollment and instructions to complete the enrollment form.

• Model Enrollment Request Form – The model enrollment form includes two sections. Section 1 includes data elements required to process the beneficiary’s enrollment. Section 2 includes mandatory data elements that the plan is required to include on the application and optional data elements, which the plan is not required to include. All data elements in Section 2 are optional for the beneficiary to complete. Plan enrollment will not be affected if the beneficiary does not complete this additional information.

The new enrollment form is considered a “model” for purposes of CMS review and approval of plan marketing materials, and plans can choose to customize the form as needed.

Additional Updates

• Model Notice Update – CMS removed information from Chapter 2 Exhibit 22 regarding the option to use an SEP to disenroll from the plan due to the loss of optional supplemental benefits because of nonpayment of optional supplemental premiums. An individual would be able to disenroll only if s/he is eligible for one of the existing SEPs.

• Electronic Signatures – As part of the Electronic Enrollment process, CMS added language that allows plan sponsors to obtain an electronic signature as an alternative to the “Enroll Now” or “I Agree” button or tool used in completing an Electronic Enrollment request. This change only applies to the Electronic Enrollment mechanism. The affirmation requirements for the Telephonic and Paper Enrollment mechanisms remain the same.
  • An electronic signature is considered to have the same legal effect and validity as a pen-and-ink signature. An organization utilizing electronic signatures must at a minimum, comply with the CMS security policies.

Where Do We Go from Here?

GHG has been assisting our clients with both development and review of required materials for over a decade. We have a long, successful history of supporting these efforts. Our team undergoes re-training every year prior to deployment of any engagement, and we have a standardized process in place that is adaptable to any of your particular needs.

If you need assistance navigating these new changes or developing sales and marketing materials for the PY2021, contact Diane Hollie today to start the conversation.

For more information on the enrollment changes, you can view the full 2021 Medicare Advantage Enrollment and Disenrollment Manual here.