Regulatory Headwinds: CMS Compliance and Oversight
The New Open Enrollment Period (OEP) January 1 through March 31
We’re all familiar with the “trial period” marketing tactic. It’s the tiny text in a TV ad that reads, “If for any reason you're not satisfied with your purchase, simply return it within the trial period.” And that’s exactly what the new Open Enrollment Period (OEP) offers, but it’s no gimmick.
The OEP is a consumer protection measure, allowing beneficiaries to select a plan during AEP and reconsider their choice January 1st - March 31st annually (read more from CMS here). And based on historical data, Cheryl O’Sullivan (VP, Strategy at Cavulus) points out that beneficiaries took advantage of the offer. In the past, clients were processing 20%-40% of their AEP application volume in the former OEP before it was eliminated. So we asked O’Sullivan for some OEP preparation tips for the run-up to 2019.
O’Sullivan put it bluntly: “training, training, training.” Regarding plan benefit education, she encourages MA plans to think beyond Sales and Member Services and not overlook Provider Outreach, Network staff, and others who disseminate plan information. She explains, “Uniform messaging and consistency will keep new members from shopping during OEP.” Now is the time for your training staff to shine. If you don’t have dedicated training resources, OEP may be the impetus to build that team or seek external help.
Communication is two-pronged, as Cheryl states:
Plans need flawless processes for internal and member communication. Sales, Call Centers, and Member Services will quickly encounter benefit designs and plan documents that are unclear to your market, so plans need efficient mechanisms to share this information internally and address them amidst the frenzy of AEP. Success in the new OEP begins on October 15th with the clarity, accuracy, and consistency plans provide.
"Success in the new OEP begins on October 15th with the clarity, accuracy, and consistency plans provide."
Along similar lines, Cheryl stresses the importance of Annual Notice of Change (ANOC) calls:
Outbound call campaigns to current members regarding key points in the ANOC will pay huge dividends, particularly if there are significant differences with drug coverage, cost structures, or network...whether good or bad. Providing transparency, explaining plan options, and reinforcing positive changes will fend off competitors and bolster retention.
“It all boils down to member confidence”, says O’Sullivan. Beyond the accuracy that any beneficiary should expect, she suggests other methods to build new member confidence including prompt application confirmation, welcome calls, and timeliness of welcome kit and ID card mailings. Given her expertise in call center operations, Cheryl also recommends plans review their call handling tiers. “Outsourced call centers should stick to CMS-approved scripts, and depending on the complexity of the question or issue that arises, escalate to various internal tiers in Sales and Member Services.”
Finally, Cheryl asks “What are you providing as a ‘leave behind' after home visits, seminars or subsequent mailings from telesales?" She concludes, “Make sure your plan contact details are front and center so you get the call.” If a new member calls an unaffiliated broker or their old plan, you may see your work in AEP come undone in Q1 of 2019.
Have a question for Cheryl? Send them to email@example.com or call 1-800-760-6915.