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.
Pros of Using Last Year’s Materials
Time savings: The CMS Model Docs contain many text alternatives that insurers must consider and choose to fit their plan offerings. Many of the choices will not change for the new year. For example, if an insurer doesn’t have pharmacies that offer preferred cost-sharing in its network, this determines which text to use in many places in the document. Using last year’s documents, which were already set up to account for this variable, significantly reduces the time spent on the document creation and review process.
Efficiencies: If an insurer is using a third-party software to create the materials – such as CodySoftÒ, a Microsoft Word add-in program like HotDocs, or an expensive composition engine like Oracle’s Documaker, then the rules and coding for creating the documents can be re-used. If an insurer has created documents manually in Word without any coding of the kind that CodySoft uses, they may be able to update their documents more easily than starting from scratch.
Consistency: Health care is susceptible to a higher rate of employee turnover than other industries. The people who created last year’s AEP materials may not be in the same positions or even with the company this year. Re-using the previous year’s documents may facilitate a consistency of style, look and feel, and retention of decisions on text choices that might otherwise be lost.
Cons of Using Last Year’s Materials
Failing to update every instance of changes in the CMS model: CMS has strict guidelines for insurers to use model text in all cases. If an insurer does not make every update dictated by the current year’s Model Docs, the insurer is at risk of errata sheets and monetary penalties. Potential pitfalls here include failing to update separate assets that exist outside the main document that have model language in them. For example, we’ve seen insurers keep as many as 60 to 70 separate files – such as the Chapter 4 Chart of Benefits (COB) and pharmacy charts – as separate Word documents. Failing to update all of these files with CMS’s model changes before the materials are finalized could lead to compliance violations.
If insurers’ plans change significantly: The benefits of re-using last year’s documents are reduced significantly if plans undergo major changes, such as adding a prescription component. Major reworking of last year’s materials would be necessary, which means starting from scratch with CMS’s model docs would likely be the better approach.
If the CMS Model Documents change significantly: For the past several years, the CMS model language has been relatively static, with only minor changes in wording; however, there is no guarantee that this will be the case this year or any year. If CMS changes the model radically – which happened several years ago – by adding new chapters, moving chapters, or changing graphics or styles, then using last year’s documents becomes impractical. If the Affordable Care Act is altered in major ways, the CMS model would likely change beyond the ability of plans to update materials based on last year’s documents.
Reducing the Risk
While updating last year’s documents have a few compelling benefits, the single biggest drawback boils down to the risk of not making every necessary change to align with CMS’s Model Documents. This is a risk we do not suggest taking. We recommend that health plans create their materials using CMS’s Model Documents, and we offer CodySoft as a solution to simplify and speed up the labor-intensive AEP materials creation process.
While programs like Microsoft Word, Adobe Acrobat, and Litera Change Pro offer some document comparison functionality that allows health plans to find and replace text, CodySoft is a robust system designed specifically for health plans to manage their materials creation. CodySoft keeps all benefit information in a data grid and uses programming to bring those benefits into documents. Users can, in one place, change the programming rule that brings the data grid values into documents to update the year and all instances of that rule in the template. This allows users to keep a single source of truth and update their benefits information quickly and easily.
CodySoft also has the ability to produce multiple plan documents from a single template. Users work in a template creation tab, out of which they can generate different plan documents from that template. That way, if there’s a change to the template, it can be made in one place and will then be automatically updated across all documents.
Health plans can use the CodySoft program directly, or have the Cody Consulting team manage materials creation for them with business processing outsourcing services. When we create our clients’ materials, we use last year’s templates for reference only. We take advantage of existing infrastructure such as updating the data grid where we maintain the benefit information and re-using rules that have been set up to automate the population of the templates.
Insurers will need to evaluate the pros and cons of starting with each year’s new CMS Model Documents versus re-using existing documents. All insurers are dependent on CMS to provide guidance on the models. Whichever method insurers pick, the more automated the processes can be and the more rigorous the reviews are, the better the documents will be when completed. For most insurers, the safest and most dependable solution is to use the new year’s CMS Model Documents.