On March 10, 2020, CMS issued key information via HPMS memo on the responsibilities and flexibilities afforded to Medicare Advantage organizations and Part D sponsors related to disasters and emergencies resulting from COVID-19.

A declaration by the Governor of a State is one of the triggering events for the special requirements related to Part A\B and supplemental Part C benefit access.  Under 42 CFR 422.100(m) the requirements are in effect until the end of the date identified in the state declaration or for 30 days if no end date is identified.  To date, declarations have been made in at least 8 states.  We urge you to follow www.nga.org/coronovirus for specific information related to your state(s) of plan operation.

When the special requirements are in effect, the requirements for MAOs are:

  1. Cover Medicare Parts A and B services and supplemental Part C plan benefits furnished at non-contracted facilities subject to § 422.204(b)(3), which requires that facilities that furnish covered A/B benefits have participation agreements with Medicare.
  2. Waive, in full, requirements for gatekeeper referrals where applicable.
  3. Provide the same cost-sharing for the enrollee as if the service or benefit had been furnished at a plan-contracted facility.
  4. Make changes that benefit the enrollee effective immediately without the 30-day notification requirement at § 422.111(d)(3). Such changes could include reductions in cost-sharing and waiving prior authorizations.

We urge you to review the HPMS memo here. and follow https://www.nga.org/coronavirus/ for specific information related to your state(s) of plan operation.

Contact a GHG expert today with any questions or if you need assistance.