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Is Your Plan Ready for the New Year?

By December 1, 2018February 8th, 2019CMS, MBI, Medicare, Open Enrollment, Part D

Annual Notices of Changes (ANOC) shared with enrollees

Evidence of Coverage (EOC) shared with enrollees

Formulary shared with enrollees

Pharmacy and Provider Directories shared with enrollees

Medicare Communications Marketing Guidelines Implemented

Claims Testing Completed

Readiness Checklist Reviewed

Don’t breathe a sigh of relief just yet.  While 1/1 is an important day for plans, there are several changes for this year that will require testing and oversight beyond 1/1.

  • Precluded Providers – Plans must comply with the new beneficiary notice and claim payment requirements regarding precluded providers, meaning all claims from precluded providers must be denied on an ongoing basis. Don’t forget to incorporate oversight of these claims in your daily denied and approved claims review. (Learn more about this in our related article,Prepared to implement the CMS Preclusion List Requirement?”
  • Enrollment/Disenrollment / Medicare Advantage Open Enrollment – In another guidance change announced as part of the Medicare Communication Marketing Guidelines (MCMG) this fall, enrollees may disenroll or switch to another MA Plan or Original Medicare or a stand-alone PDP during the Medicare Advantage Open Enrollment Period, which begins on January 1 and now ends on March 31. This means customer service must also operate extended hours for 7 days a week, 8:00 am to 8:00 pm, through March 31.
  • Medicare Beneficiary Identifier (MBI) – CMS will move to the MBI system in April 2019. Plans should already be ensuring that all systems are ready for this change and be prepared to use the MBI in the crosswalk for data submission to CMS systems.

These edits will need to be monitored on an ongoing basis and included in daily denied and approved claims review and as part of an ongoing drug management program.

Before ringing in the new year, ensure your plan is ready.  There are many pieces of new guidance that impact 2019, so ensure your compliance and operations have carefully reviewed them for all the changes and implications.

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