Within the Final Rule, the Centers for Medicare & Medicaid Services (CMS) confirmed the reinstatement of the Open Enrollment Period (OEP), which allows a one-time enrollment election from January 1 – March 31 beginning in 2019. For those of us who have been in Medicare Advantage (MA) for a while, we may have had a few déjá vu moments with this announcement (or was that just me?). When we start really thinking about the reinstatement of the OEP, we may be tempted to dust off those old OEP strategies. However, from our perspective, reemploying old strategies would be a mistake. For new plans, or those new to MA, who have never been through an OEP, there is even more to consider from a strategic perspective. While we wait for the Final Medicare Marketing and Communication Guidelines, as well as the Enrollment Guidance, which will tell us where the OEP will fall in the hierarchy of enrollment periods – here are some things to start thinking about:
The reinstatement of the OEP fundamentally changes your sales and marketing strategy. While CMS states we cannot actively market the OEP to beneficiaries, we are permitted to educate. Now is the time to start thinking about how you will educate in a compliant manner – keeping in mind that CMS will undoubtedly provide more prescriptive guidance when the Marketing Guidelines are released.
Your member onboarding and retention program is more important now than ever before. Your newly enrolled members can be easily lost in OEP if their initial experience with your plan is not positive. Now is the time to review and enhance your member onboarding and retention program to ensure that you are ready on January 1st.
The 5-star Special Enrollment Period (SEP) and the OEP will exist for the first time together in 2019, therefore:
- If you are a 5-star plan, start thinking about how the OEP will change your strategy during and after OEP.
- If you are not a 5-star plan but have a 5-star plan in your service area, start thinking about how this should impact your strategy after OEP – retention, retention, retention!
As we wait for CMS’ final guidance related to the specifics of the new (old) OEP, what we do know is that our sales and marketing strategies must change, and member retention is more important than ever before.
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