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| NAHU Submits Comment Letter on Proposed Changes to Medicare Programs |
NAHU submitted comments to CMS this week in regard to the Contract Year 2021 and 2022 Medicare Advantage and Part D Proposed Rule. The proposed rule dealt with look-alike plans, ESRD beneficiaries, training and testing requirements, beneficiary contact and more. We wrote our comment letters with the informative input from our Medicare Advisory Group.
Here is a summary of our comments:
- We expressed our support of limiting access to “look-alike” plans (MA plans designed to be extremely similar to D-SNPs) since they are not subject to the same federal and state regulations. We made it clear that our Medicare agents and brokers do not tolerate misrepresentation.
- We stated that marketing and advertisements should be restricted during the MA OEP, due to its potential to confuse seniors and make beneficiaries think they need to make unnecessary plan changes.
- In regard to beneficiary contact, we suggested that CMS add specific prohibition on unsolicited “robocalls.” We also noted that the contact provision currently allows individuals who already have an established agent relationship to receive many unsolicited and confusing calls from their carrier, so we requested that it be amended to allow contact unless the member has an external agent of record.
- The proposed rule eliminates provisions regarding referral fees in order to clarify CMS’s intent that compensation be on a per-enrollment basis. We commented that, while NAHU understands the intent behind it, the proposal will not fully address the problems in the marketplace regarding referral fees. We suggested greater coordination with the state departments of insurance to enforce existing regulations.
- We suggested that CMS consider providing relaxed training and testing requirements for individuals who have been certified with at least one MA issuer for five years or longer.
- We requested that references to prorated commissions be eliminated, as requirements related to prorating payments are nonsensical and unfair to Medicare agents.
- The proposed rule intends to carry out the requirements under the 21st Century Cures Act to allow ESRD patients who already qualify for Medicare to join an MA plan. We noted our concerns that this will increase costs for all MA beneficiaries, and that CMS should provide carriers with additional methods of accounting for these increased costs.
- We noted our support for the provision that would increase the weight of patient experiences, complaints and access measures in the quality rating star methodology.
- The proposed rule would allow Part D to establish a second, “preferred” specialty tier with lower cost sharing than the current specialty tier and creates other related requirements. We supported this idea, but noted that CMS must ensure that any new pricing design is clearly communicated in the Medicare Plan Finder tool and any other relevant tools.
- The proposed rule would require each Part D plan to implement a beneficiary real-time benefit tool to allow enrollees to view plan-provided, patient-specific, real-time formulary and benefit information both online and through the plan’s customer service call center. We raised concerns that this would both undermine the existing Medicare Plan Finder, which was designed to be the centralized tool to efficiently inform all beneficiaries what they need to know. We suggested that the MPF be fixed and updated with any additional information CMS wants to include, rather than creating several new tools.
- In regard to a proposal to standardize pharmacy performance measurement tools and increase transparency in Part D, we noted that most beneficiaries would not place much value on star-rating metrics, and that any efforts related to pharmacies should focus on lowering drug costs.
- We strongly opposed the proposed rule’s changes to the medical loss ratio, which would remove a potential deterrent to the offering of MSAs by MA organizations that may be concerned about their inability to meet the MLR requirement as a result of random variations in claims experience.
- We expressed our support for two new SEPs but requested that if a beneficiary who is eligible for any of these new SEPs or any other SEP has an agent of record, that a pathway be created for the agent of record to make the plan change.
- We recommended that all MA plan types, including preferred provider organizations, be permitted to offer telehealth through non-contracted providers and to treat them as basic benefits under MA.
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