With a new year right around the corner, we asked our team of experts: What can health plans expect in 2018?
Listed below are a few issues health plans should be aware of and keep an eye on as we move into the new year. These cover the areas of compliance, technology, and member marketing materials creation and production.
Vice President, Technology
With the increasingly growing concerns with data breaches, security, and HIPAA and HiTech regulations getting tighter and tighter – health plans can expect more rigor around the risk and InfoSec management of people, processes, vendors and associated technologies. It will be important for health plans to find, select and vet the right partners and people.
In addition, as regulations and related financial penalties increase and tighten year over year – a need to have more automated, auditable technologies in place is mission critical. Given the security, efficiencies and error-reduction that automated technologies provide, it will be critical for health plans to implement these solutions, or more of these solutions, as they move forward.
Director of Consulting
A potential update for Contract Year 2019 is the Centers for Medicare & Medicaid Services’ (CMS) proposed change to the required delivery date for the Evidence of Coverage (EOC). CMS is proposing that plans must provide the EOC to members by the first day of the Annual Election Period (AEP). For Contract Year 2018, plans were required to distribute both the ANOC and the EOC to members by September 30. This proposed change would allow plans an additional 15 days to develop and distribute their EOCs.
Health plans can expect CMS to continue its focused reviews of common findings in CPE program audits. The common findings continue to be a focus of CMS for two reasons:
1. The average number of CPE conditions has dropped from 38 in 2012 to under 18 in 2016; and
2. The number of four- and five-star plans has increased so that in 2018, CMS expects approximately 73 percent of Medicare Advantage enrollees with prescription drug coverage to be enrolled in four- and five-star plans.
Both operative outcomes reflect overall increased plan performance and audit performance. Therefore, audit findings should continue to decrease and remain within the common findings realm, meaning there should be no surprise audit findings by CMS.
One interpretation of this analysis is that CMS may turn its attention to poor plan sponsor performers and newer plan sponsors who may become focus for 2018 program audits. If so, then these plan sponsors should pay heed to past common findings and prepare their organizations for audits by addressing these known issues.
ePresentment is a term used to describe the distribution of materials via electronic means in lieu of conventional print and mail. As part of the Annual Notice of Change/Evidence of Coverage (ANOC/EOC) Instructions that CMS publishes, “MAOs, PDPs, and Cost Plans may include an “opt-in” form in the ANOC/EOC mailing to receive the CY 2018 ANOC/EOC electronically.” In addition to making ePresentment of the ANOC materials an option that Plans can offer, CMS Administrator Seema Verma recently announced the “Patients over Paperwork Initiative,” which would potentially allow plans to electronically distribute “Certain Beneficiary Documents,” and further proposes to “separate the delivery date of the Annual Notice of Change (ANOC) from the Evidence of Coverage (EOC)” and “to provide CMS with the ability to permit MA and Part D sponsors to provide certain materials, such as the EOC, electronically.”
It is clear that allowing plans to electronically distribute required member materials would dramatically reduce the amount of physically printed and mailed materials, and reduce their fulfillment costs and turnaround times. It is also clear, however, that plans will need a compliance minded mechanism to allow Members to “opt-in” to ePresentment, bifurcate fulfillment data into electronic versus regular mail streams, store member-specific document sets, and track member responses and distributions. Cody Consulting’s integrated approach to managing compliance, document development, and data management can make managing a Plan’s transition to ePresentment simple, efficient and cost-effective.
On a related front, Revised 508 Standards for website and electronically distributed materials have been released as part of the “508 Refresh.” These 508 Standards became effective as of March 21, 2017, and have a compliance deadline of January 18, 2018, for all government agencies and contractors. As part of these new and more defined Standards, CMS will now have a clear and precise way of analyzing and measuring a PDF document’s 508 compliance, so plans should be aware of the need to globally review websites and distributed PDFs, and ensure that their 508 remediation teams have the ability to guarantee compliance with all current 508 guidelines.