Mandated Member Communications: Early Release of CMS Guidelines

Between last week's 245-189 vote on H.R. 2 and President Obama's statements on healthcare reform during the State of the Union, it has been an exciting start to 2011 from the healthcare perspective.

Before any more breaking news happens, I wanted to share some thoughts on the Center for Medicare and Medicaid Services working hard to quickly develop and issue their regulatory guidance. The new draft of the 2011 Medicare Marketing Guidelines was issued not too long ago and the timing of this is unprecedented due to it arriving approximately 6 – 12 weeks earlier than normal.

While this is highly unusual, it aligns with the events of the past two weeks. By putting forth these guidelines, it is evident that CMS is wasting no time keeping in stride with the current administration’s drum beat in light of the daily discussions around repealing the Affordable Care Act.

In addition to issuing the draft of the guidelines earlier, CMS has already issued the following regulations ahead of schedule:

• Release of 2012 Part C, Part D, Special Needs Plan (SNP) and Employer/Union-Only Group Waiver Plan (EGWP) Application
• Issuance of the Revised Draft 2012 Medicare Marketing Guidelines
• Premium Withhold for January 1, 2011 Enrollment
• Coverage Gap Discount Program: Participating Labeler Code Update
• Issuance of Final Update to Chapter 1 of the Medicare Managed Care Manual
• CY 2011 Formulary Updates
• Final Medicare Part D Reporting Requirements for Contract Year (CY) 2011
• Special Enrollment Period for Individuals Under 65 to Purchase Medigap Policies
• Clarification of Medicare Advantage Disenrollment Period

As someone that loves staying a step ahead in the healthcare communications field, I live by the motto, "the sooner, the better" when it comes to regulatory updates. It allows me and my colleagues to better serve our clients by having the knowledge to customize services, technology solutions and methodologies to the market changes. This also equips us with the intelligence to converse with our current clients and prospects on regulatory matters that affect their world, showing them we have top-tier expertise in rapid response that sets us apart in the marketplace.

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Pam Argeris is a thought leader in the Healthcare Industry and possesses extensive, hands-on experience with CMS compliance, and multiple regulatory bodies such as NCQA, JACHO, and DOI. In her role at Merrill Corp., Pam focuses on developing solutions for compliance and quality assurance, delivered in a cost effective manner to improve beneficiary and prospect communications. Pam can be contacted at Pamela.Argeris@merrillcorp.com.

What the 245 - 189 Vote Means for Health Plan Communications

On January 19th, the U.S. House of Representatives voted 245-189 on H.R. 2, a bill to repeal the Patient Protection and Affordable Care Act. This, combined with the introduction of H.R. 9, indicates that, while these actions appear to be symbolic in nature (due to the lack of traction it is expected to have in the Senate and President Obama's commitment to veto), the political battle surrounding the Health Care Reform and the Affordable Care Act will continue to heat up.

The law is going to continue to evolve and change, making it essential for plans to have reliable, flexible partners to help them adhere to the new regulations and stay ahead of changes. As news continues to pour out of Washington, I will continue to deliver news, reactions, analysis and potential repercussions via the Merrill Healthcare Blog. 

As an example, below are excerpts from HHS Secretary Kathleen Sebelius's remarks in reaction to the vote (Healthcare plans should pay specific attention to her last quote):

“Thanks to the Affordable Care Act, Americans are finally getting the freedom and security they deserve in their health care."

“Over the last ten months, I have seen firsthand how the law is making a difference in Americans' lives, from establishing a new Patient’s Bill of Rights that outlaws some of the worst insurance company abuses to beginning the process of ending insurance company discrimination against the 129 million Americans with pre-existing health conditions."

“If the law were repealed, these protections would be taken away, and America’s seniors would lose important new Medicare benefits, including savings on their prescription drugs and new health and wellness benefits."

“A recent analysis by our Department shows that the Affordable Care Act will sharply reduce the cost of health insurance for millions of Americans. A family of four making $55,000 is projected to save $6,000 a year in 2014. For a working family with a $33,000 income, the savings could be up to $10,000 – the difference between being able to afford health insurance and going without it.

“Repealing the Affordable Care Act would raise health insurance costs for families, add to our federal deficit, put control back in the hands of insurance companies, and take away the freedom and health security being realized by millions of Americans. That would be the wrong direction for our country, and would be disastrous for the health and well-being of American families.”

“Finally, I want the people who are benefiting from the Affordable Care Act – including families, seniors, and small business owners – to know that this vote does not change the law and that this Department will continue to work every day to implement this vital law.”

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Pam Argeris is a thought leader in the Healthcare Industry and possesses extensive, hands-on experience with CMS compliance, and multiple regulatory bodies such as NCQA, JACHO, and DOI. In her role at Merrill Corp., Pam focuses on developing solutions for compliance and quality assurance, delivered in a cost effective manner to improve beneficiary and prospect communications. Pam can be contacted at Pamela.Argeris@merrillcorp.com.

Mandated Member Communications: A Case Study (Part 2)

Last week, we presented a scenario that, while specific in nature, has commonalities to what a number of organizations in the healthcare communications space may have to deal with when confronted with.the resource-draining, time-consuming process that is the preparation, distributing and reporting of CMS mandated member communications.

A nationally-known insurance company lacked in-house capabilities for managing the creation and distribution of mandated letters for their Medicare members. This resulted in inaccurate mailings, missed deadlines, and poor CMS audit results.

THE SOLUTION:

A web-enabled solution was created that systematically worked with the organization's data and married it to the correct CMS-approved template. The final document was then printed and distributed in one automated process.

This solution provided a chain of custody workflow that was desired by the organization and adhered to all CMS Chapter Two requirements and regulations. Furthermore, the built-in quality assurance processes validated the quality attributes of the letters and delivered 100% integrity management through the utilization of a 2-D bar code driven production process. Additionally, robust tracking – from file creation to delivery point validation, provided detailed, on-demand reports in response to any audit requirements.

This solution effectively transitioned a resource-draining, error-prone process
into a highly efficient, automated data management system. Utilizing HIPAA/PHI
compliant workflows and SAS 70 certified production and mailing facilities, the organization achieved 100% accuracy on all letters managed through this solution. Advanced SLAs provided same day delivery on all files received by 4 a.m., and overall program efficiencies delivered an immediate 20% cost reduction. Additionally, the organization leveraged proactive monitoring of regulatory changes to remain in compliance, at no effort to them.

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Pam Argeris is a thought leader in the Healthcare Industry and possesses extensive, hands-on experience with CMS compliance, and multiple regulatory bodies such as NCQA, JACHO, and DOI. In her role at Merrill Corp., Pam focuses on developing solutions for compliance and quality assurance, delivered in a cost effective manner to improve beneficiary and prospect communications. Pam can be contacted at Pamela.Argeris@merrillcorp.com.

Mandated Member Communications: A Case Study

At the end of 2010, we discussed in abstract the resource-draining, time-consuming process that is the preparation, distributing and reporting of CMS mandated member communications, highlighting how the enactment of the Affordable Care Act and tightening regulatory guidelines have only compounded this already trying process and how the penalties for non-compliance include monitoring, fines, and the risk of contract non-renewal.

We wanted to start 2011 off with a scenario, and while this is a true case study, we believe that there are aspects of this specific issue that are relatable to a number of organizations that are part of the healthcare marketing space:

THE CHALLENGE:

A nationally-known insurance company was having difficulty managing the creation and distribution of mandated letters for their Medicare members. They lacked an in-house solution and their current production vendors could not manage the growing volume, facilitate mass template changes nor provide adequate reporting. This resulted in inaccurate mailings, missed deadlines, and poor CMS audit results. 

Additionally, the organization realized that in an effort to improve their CMS Five-STAR Rating, they needed to reduce the amount of appeals and grievances filed with CMS as a result of non-compliant communications.

Next week, we will discuss the solution that was developed that helped both reduce costs and improve workflow.

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Pam Argeris is a thought leader in the Healthcare Industry and possesses extensive, hands-on experience with CMS compliance, and multiple regulatory bodies such as NCQA, JACHO, and DOI. In her role at Merrill Corp., Pam focuses on developing solutions for compliance and quality assurance, delivered in a cost effective manner to improve beneficiary and prospect communications. You can contact Pam at Pamela.Argeris@merrillcorp.com.