Thursday, January 27, 2011

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.

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

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