Over the last several years, The Centers for Medicare and Medicaid Services (CMS) has taken an increasingly tough stance on health plans that distribute Annual Notice of Change (ANOC) and Evidence of Coverage (EOC) documents with unclear and/or inaccurate benefit information.
CMS is no longer sending health plans warnings for these errors; they are imposing civil money penalties (CMPs) for thousands of dollars that health plans must pay. For instance, CMS recently imposed a CMP in the amount of $132,000 to a health plan for failing to provide accurate benefit information to 2,400 enrollees in its Contract Year (CY) 2017 ANOC and EOC documents. For larger health plans, fines can quickly add up to millions of dollars.
CMS’s reasoning behind these fines is that if members receive inaccurate information related to premiums, deductibles and co-pays, they may enroll in a plan under false expectations. Read more »
Are Your Materials Section 508 Compliant?
Any time health plans prepare an electronic document that will be posted online or distributed via e-mail, the material needs to meet current Section 508 standards of the Rehabilitation Act. This is true of both internal and external documents. Failing to meet these requirements can result in fines and sanctions from the Centers for Medicare & Medicaid Services (CMS).
While most health plan compliance and marketing professionals understand the basics of Section 508, many are not up to date with the specific requirements of the recent 508 Standards Refresh.
Document Accuracy Assessment helps identify errors before CMS
The creation of your Annual Notice of Changes (ANOC) and Evidence of Coverage (EOC) document is a very challenging process and can be a strain on already over-taxed resources. Ensuring the accuracy of these documents is extremely important, as CMS has taken an increasingly tough stance on plans that distribute documents with unclear and/or inaccurate benefit information.
If you’re like most health plans, you could use a few extra set of eyes to review your final materials to ensure accuracy.
Backed by our team of model document experts, our Document Accuracy Assessment services can identify inconsistencies and errors in your plan documents that could negatively impact members and cause CMS to take action against your plan. Cody’s Document Accuracy Assessment service allows you time to self-report these errors before CMS’ Oct. 31 deadline for self-reporting. Read more »
CodySoft® Adds Part C and Part D Reporting Feature
CodySoft® has added a new feature to its Investigations Module®, making it easier for health plans to pull their Part C and Part D reports on plan oversight of agents.
Even though the Centers for Medicare & Medicaid Services (CMS) no longer requires this report in the annual Part C and D reports, health plans cannot afford to be lax in their reporting and monitoring of the sales force and marketing activities. The regional CMS office can require health plans to submit this report at any time.
CodySoft® Adds Markup Tool to its List of Features
CodySoft® has added a Markup Tool feature to its Collateral Management Module®, making it easier for users to make, review and accept edits to health plan member marketing materials, such as Annual Notice of Changes (ANOC), Evidence of Coverage (EOC) and Summary of Benefits (SB) documents.
“In a typical scenario, health plans may pass one document around to 30 different people for review via email, and then have to make sense of the edits made to 30 different files,” said Brian Yavorsky, vice president of technology at Cody. “Our Markup Tool lets all users make their suggested edits in one document that’s kept in the Collateral Management Module, eliminating all that legwork and decreasing the chance of errors.”
What Health Plan Marketing Pros Don’t Know About Working with Vendors Can Hurt them
As health plans race to create and distribute Calendar Year 2018 Annual Notice of Changes (ANOC) Packages, most member marketing teams know time is of the essence. But, many aren’t aware of a few particular areas that could potentially hang them up, which is the last thing they want to happen when they’re under the gun.
Even if the health plan has ironclad policies and streamlined procedures, working with multiple outside vendors can pose risks. Each vendor operates according to its own procedures and its own timeline, and vendors caution that meeting plan deadlines is dependent on other vendors’ timely and accurate deliverables. Like a relay race, every time materials change hands, there’s a chance the baton will be fumbled or dropped. And, the more vendors that are involved in the materials creation and fulfillment process, the more the risk of delays and errors increases.
Industry Alert: Iowa Senator Calls for Greater Scrutiny of MA Plans
Kaiser Health News recently published an article about Senator Chuck Grassley (R-Iowa) asking federal health officials to tighten scrutiny of private Medicare Advantage (MA) health plans. His request comes amid ongoing concern that insurers over-bill the government by billions of dollars every year.
In mid-April, Grassley wrote a letter to Centers for Medicare and Medicaid Services (CMS) Administrator Seema Verma, citing an article that alleged billing discrepancies. He has asked CMS officials to explain why they failed to collect nearly $125 million in potential overcharges identified at five Medicare Advantage plans audited in a single year.
The Pros and Cons of Updating Last Year’s AEP Materials vs. Using CMS’s Model Docs
The Centers for Medicare & Medicaid Services (CMS) will release its 2018 Model Documents for Annual Enrollment Period (AEP) materials any day. When it does, health plans will face the same question they face year after year – do we start fresh using this year’s Model Documents or update last year’s materials?
With Annual Notice of Changes (ANOC) averaging around 25 pages and Evidence of Coverage (EOC) documents averaging around 250-300 pages, getting AEP materials into members’ hands by September 30 means there is no time to waste. Generally speaking, using CMS’s Model Docs carries less risk; however, having to construct new documents from the CMS model every year is extremely labor-intensive.
The past several years, CMS’s Model Documents have been composed of roughly 90% boilerplate text that has varied little each year. With the exception of insurers that are consolidating plans or creating new ones, most annual changes to benefits, copays and other aspects of coverage are relatively minor. This may make updating last year’s materials an attractive approach when compared to the thought of using CMS’s model. On the flip side, there also are significant reasons using previous years’ documents might not be the best method.
It’s critically important to understand the following pros and cons when considering whether to update last year’s AEP materials or use CMS’s model docs.
Best Practices for Language beyond the CMS Model Language
The Centers for Medicare and Medicaid Services (CMS) templates for the Annual Notice of Changes (ANOC) and Evidence of Coverage (EOC) contain extensive model language that is required and must be used by every insurer. However, there are also numerous places in these documents where health plans have latitude and flexibility to use their own language to describe benefits, cost-sharing, coverage limits and so forth. These areas provide significant opportunities for health plans to better communicate with their members, and thereby positively impact the member’s experience.
The Secret to Simplifying Health Plans’ Member Marketing Material Translations: A Parallel Project Path
We’ve seen first-hand the frustrations health plan project managers experience in translating their member marketing materials – including Annual Notice of Coverage (ANOC), Evidence of Coverage (EOC), Drug Formulary and Summary of Benefits (SB) – to additional languages.
The question for our CodyPrint® team became: What would give project managers visibility to the translation process, minimize the production timeline, and eliminate the iterative processes that increase the opportunity for errors in these materials?
The answer was a parallel project path for creating both the English and Spanish versions of these materials in lockstep. Rather than the conventional model where the health plan gives a translation company an English document to translate, the translation company does its work and then sends the translated document back, we developed a different methodology to create and revise English and Spanish documents in parallel.