CMS has proposed a number of changes for 2019 that would be agent- and client-friendly. This may be the one of the best reads I have had with CMS proposals. The comment period was over January 26 and NAHU gave CMS its feedback. If implemented as proposed, here are some of the highlights:

1. Opioids will be more heavily scrutinized with greater review for those given prescriptions. For clients suffering real pain, the drugs won’t be denied, but over-prescribing will be prohibited.
2. Seamless conversions, when a carrier moves a client from individual under-65 coverage directly to a Medicare Advantage plan, will be prohibited. Clients will have to opt in rather than opt out, with the dual-eligible population as the sole exception.
3. Open enrollment switch period replaces the Medicare Advantage Disenrollment Period beginning 1/1/2019. This one-time switch allows a client to make a change in Medicare Advantage plans between 1/1 and 3/31 annually. This would be very helpful to the clients who regret their Annual Election Period selection perhaps due to network or formulary restrictions.
4. Dual-eligibles would be able to make a switch to another Special Needs Plan once per calendar year rather than unlimited changes in a year, as it is today.
5. “Meaningful Difference” has been a rule by CMS that required an actuarial difference for a carrier in offering Part D and Medicare Advantage plans. These rules are being relaxed to encourage more competition and consumer choice. Expect to see carriers offering three Part D plans instead of two starting in 2019. Also expect to see more creativity in plan designs.
6. Reduced paperwork and approvals are being proposed, especially for marketing materials unlikely to directly result in an enrollment. Expect fewer required pieces needing a CMS approval code in 2019.

NAHU is very supportive of the direction taken by CMS in making changes to the program that are more consumer- and agent-friendly.