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!
CMS also recently held its 2017 Audit and Enforcement Conference. Our Senior Vice President of Compliance Solutions, Regan Pennypacker, provides a recap here >>
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