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The Importance of Medicare Marketing Material Development and Review, New changes coming and 2024 finding examples

Member materials are an important part of the Medicare member experience with a plan. Each year as Plan Sponsors finalize their product bid filing, CMS releases the upcoming plan year models of key materials needed for the Annual Enrollment Period and beyond. It is crucial for plans to ensure that all information provided directly to members is accurate and provided within required timeframes. Failure to do so can result in errata, Notices of Non-Compliance (NONC), or even Civil Money Penalties (CMPs) for the Plan Sponsor. Additionally, incorrect member materials may have downstream operational impacts on member call centers, claims payment, and plan providers- just to name a few! For CY2025, BluePeak is expecting significant Part D model and operational language changes that plans should be prepared for.

In 2022, the Inflation Reduction Act introduced the Medicare Prescription Payment Plan to the industry with an effective date of January 1, 2025. Part D plan sponsors must include information about the Medicare Prescription Payment Plan in required Part D communications materials, including on their websites, member ID card mailings, and notices to enrollees (e.g., Evidence of Coverage, Annual Notice of Change, and Explanation of Benefits documents). CMS is developing new model materials to support Part D plan sponsors in communicating with current and prospective Medicare Prescription Payment Plan program participants. CMS has stated these materials will be available in the summer of 2024, which leads us to believe the anticipated changes will not be part of the model materials released in May 2024.  The addition of newly required materials after development has begun for most plans will cause additional work for Plan Sponsors and risk inaccurate materials that may require errata.

Each year, BluePeak supports plans with marketing material review and marketing material development.  In 2024, BluePeak supported a plan who was experiencing turnover in the marketing department and transition to an automated material creation tool.  Standup of the automated tool takes at least three years of development, coding, and use to produce quality results. During that time, CMS will continue to release model changes which also require updating of the automated tool.  Our support was to review the output of the tool and identify errors.  BluePeak identified significant areas where the model changes were not made, but also many language changes that were not consistent with plan operations.

On another project in 2024, BluePeak was asked to develop required marketing materials for a plan with limited resources.  Our engagement included reviewing current plan designs and intended changes with the plan so they could understand how they would be reflected within the materials. By using the existing materials, we were able to update benefits and new model language to form a compliant and accurate document.

Plan materials for 2025 are gearing up to have more content changes than we have experienced in quite some time.  Plans should engage early with their internal teams and BluePeak as a partner to ensure these anticipated model changes can be accurately included in materials and that their operational practices of the Medicare Prescription Payment Plan are compliant with CMS expectations. Considering the short turnaround time between model material release, plan bid filing, National Average Monthly Bid Amount (NABA), CMS required changes (late August/early September), and mailing dates, now is the time to start planning and securing resources for this important work!

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