CMS proposed rule impacts MA marketing and enrollment

The Centers for Medicare & Medicaid Services Contract Year 2027 Proposed Rule contains a number of provisions impacting Medicare Advantage and Medicare Part D prescription drug plans. What do Medicare agents need to know about these changes?

Josh Slattery, executive vice president of The Brokerage Inc., and Michael Hedge, senior director of government relations with the National Association of Insurance and Financial Advisors, outlined what agents must know during the recent NAIFA Medicare Collective Impact Day.

The proposed rule was released in November with comments due by Jan. 26. The final rule is expected between April and June. The proposed rule does not set payment rates. It addresses policy and operational rules governing how plans design benefits, report quality, market plans and administer drug coverage.

Slattery said key provisions of the proposed rule include:

• Adjustments to marketing and enrollment rules.

The proposed rule would eliminate the 12-hour rule delay between educational and marketing events in the same location. It would allow a marketing event to directly follow an educational event in the same location, provided an appropriate break is included.

Scope of appointments would be allowed to be collected during educational events, as long as the actual marketing discussion does not begin until after the SOA is signed.

Agents and brokers would have more flexibility to conduct events. This would potentially improve marketing effectiveness and remove compliance bottlenecks.

Beneficiaries would need clearer communication from agents to be sure they understand when education ends and sales start, but they also would obtain quicker access to plan information.

The proposed rule would modify special enrollment period regulations to allow enrollees to change plans when one or more of their providers are leaving their plan’s network.

The mandatory 48-hour waiting period between completing an SOA and holding a personal marketing appointment would be removed under the proposed rule.

Agents and brokers still must retain enrollment records for 10 years, but the proposed rule would reduce marketing and sales call recording retention requirements from 10 years to six years.

• Revisions to the Star Rating system.

 The proposed rule would impose a major redesign of the system, removing 12 measures from plans. The rule also would implement a rebalanced weighting model that shifts the mix across the Consumer Assessment of Healthcare Providers and Health Outcomes Survey, the Healthcare Effectiveness Data and Information Set, and Pharmacy and Quality Improvement.

The goal is to refocus the program on clinical care, outcomes and patient experience while reducing administrative burdens on plans.

• Removal of the Health Equity Index reward.

Plans must now design around clinical outcomes, closing gaps, reducing disparities and earning member trust.

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Susan Rupe is managing editor for InsuranceNewsNet. She formerly served as communications director for an insurance agents' association and was an award-winning newspaper reporter and editor. Contact her at [email protected].