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.

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.

Mandated Member Communications: The Most Important Parts of the Census to Health Plans

With the 2010 Census information released this week, it will be interesting to see the demographic shifts across the U.S. While to the general public, understanding how the population is shifting is a “nice to know," for health plans, this new information from the Census will directly impact how they operate their business. 

With the passing of the Centers for Medicare & Medicaid Services (CMS) 10% Translation Rule, health plans that sell products in either Medicare or Medicaid are required to provide all their materials in an alternative language if over 10% of their population in a specific area speaks that language as their primary. CMS and other regulatory bodies are not only requiring this, but also heavily enforcing it – with increased auditing and secret shopper activities ensuring the available and accurate translation of these materials.

While the Rule has been in effect for a few years now, a recent study by the National Senior Citizens Law Center (NSCLC) found that many Medicare Advantage plans and Medicare Part D plans are not publishing marketing materials in Spanish as required by CMS under their provider contracts.

This study shows just how widespread non-compliance of translated marketing materials is. To make matters worse, this study does not take into account the compliance requirements for pre enrollment, post enrollment and mandated communications – which means the likelihood of non-adherence or inaccuracies in these materials is most likely even greater than reported in this study. This should be alarming for any health plan, as any inaccurate or missing translated materials could have devastating effects on their ability to market themselves if CMS enforces penalties against them.

As the population of the United States continues to change, the number of areas with required translation needs and the number of languages that will be required will continue to grow. With these changing demographics, the need for accurately translated member communications - including marketing, pre enrollment, post enrollment and mandated communications - will continue to be a driving component to the viability of a health plan.

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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.

Mandated Member Communications: It’s the Most Wonderful Time of the Year?

“It’s the most wonderful time of the year

with the kids jingle belling and 

everyone telling 

you’ll be of good cheer

It’s the most wonderful time of the year.”

Let me be the first to say that it’s pretty clear Andy Williams did NOT work at a health plan!!

While he is singing about parties for toasting and marshmallows for roasting, the rest of us are neck deep in the enrollment season and the stress, long hours and craziness that go hand-in-hand with this supposed “most wonderful time of year”.

Health plans are in the middle of orchestrating a successful enrollment season. With three major communication initiatives occurring, plans must create, produce and distribute Agent/Broker Communications, Pre-Enrollment materials and Post-Enrollment materials accurately, on time and within compliance. Any mistake made along the way can have a devastating effect on the plan’s ability to attract or retain members. Because of this, plans have a laser focus on these activities ensuring they are executed flawlessly.

Often lost amongst all these activities is another major initiative that needs to be handled with kid gloves: Preparing and executing mandated post enrollment communications. While these communications often fly below the radar during this time of year, they can have a major impact on a business if they are not handled properly. With changing regulations, new exhibits and addendum, and increased monitoring by regulatory bodies, failure to adhere to the requirements can lead directly to penalties for non-compliance including monitoring, fines, and the risk of contract non-renewal.

While the other communications rightfully get most of the attention and resources, don’t let mandated member communications be the straw that breaks the camel’s back. Preparing, distributing, and reporting on mandated member communications is often a resource-draining and time-consuming process, and with the enactment of the Affordable Care Act and tightening regulatory guidelines, the process has only been compounded. Worse, failure to comply with strict service level agreements and deadlines can result in penalties, including monitoring, fines, and the risk of contract non-renewal. Taking the proper time will build positive momentum and will ensure that all your other enrollment activities were not for naught.

And you know what, if all of these communications are executed properly, this year’s enrollment season could very well end up being "the most wonderful time of year" for your plan.

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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.

Mandated Member Communications in Healthcare: An Introduction

Preparing, distributing, and reporting on mandated member communications is often a resource-draining and time-consuming process. The enactment of the Affordable Care Act and tightening regulatory guidelines have only compounded this already trying process. Worse, failure to comply with strict service level agreements and deadlines can result in penalties for non-compliance including monitoring, fines, and the risk of contract non-renewal.

Today, this blog is commencing a series on the topic of mandated member communications, including the different types that currently (and potentially) could exist, as well as new methods for companies to improve their process for staying compliant.

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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 her at Pamela.Argeris@merrillcorp.com.