Thankfully, yesterday’s challenges can be learning opportunities that help us improve in the future. The following are four lessons learned leading up to the 2015 AEP that will help health plans better prepare for creating ANOCs and EOCs next year:

Lesson #1: A comprehensive timeline is key to success

One challenge some MA and PDP plans faced this year was the absence of a formalized timeline for developing and distributing materials. With little time to collect information and create documents after The Centers for Medicare & Medicaid Services (CMS) releases its ANOC and EOC model documents, developing a comprehensive timeline well in advance is key to staying on schedule and distributing materials on time.

It’s also important that this timeline be flexible, as delays from CMS may push back schedules and require that health plans hurry up and then wait, or worse, vice versa. Next year, make sure you have a timeline that has enough padding to adjust for delays.

Lesson #2: Key contributors should be identified early

When developing their ANOC and EOC documents for the 2015 AEP, many plans neglected to proactively identify the cross-functional team needed to ensure that materials were accurate, on schedule and in compliance. As a result, identifying and gaining the commitment of subject matter experts (SMEs) to review documents for accuracy and compliance came as a bit of a challenge.

When not all departments are adequately involved in this process, plans risk distributing materials containing mistakes or errors. To alleviate this problem, plans should identify key contributors and build a cross-functional team early on in the process. This should include SMEs from all relevant areas of the organization who can provide timely review of content and ensure accuracy of information.

Lesson #3: Clear leadership should be established

While establishing a cross-departmental team is an important part of success for the AEP document creation process, every team needs a leader. Health plans that did not have a dedicated individual responsible for guiding the materials creation process and all its players may have risked wasting both time and money, and increased their risk of non-compliance.

Additionally, if this individual did not have cross-departmental authority, precious time was wasted on gaining cooperation from individuals not within the project leader’s reporting structure.

Next year, prior to selecting a team or establishing a timeline, a leader within the organization should be appointed to manage the ANOC and EOC materials creation process from beginning to end. Ideally, this person will have limited work commitments aside from this project to ensure a dedicated focus. They must also have the authority to push the process forward, make decisions and obtain content and approvals from other team members.

Lesson #4: Software should be used to increase efficiency and compliance

During the 2015 AEP prep season, health plans that used a software tool to help manage the materials creation process had an easier time coordinating all the different moving parts involved. In addition, they likely reduced their risk of document errors, costly errata mailings, and late project completion – not to mention dramatically decreased the stress levels of project participants.

Tools are available that help health plans manage all aspects of development, tracking and distribution of these required materials, and many successful plans integrate these software solutions into their materials creation process. If they have not already, plans should start exploring tools that facilitate a comprehensive approach to marketing collateral needs.

A powerful tool will include modules that manage scheduling, compliance, document creation, as well as overall project management. And don’t forget, individuals on the materials creation team must be fully trained to use these tools. After all, what good is a solution that streamlines processes if those within the organization do not use it properly or to the full extent of its capabilities?

The good news is the 2015 ANOC and EOC mailing project is done – you’ve made it through. Now, let’s use the lessons learned and make next year even better.

by Al Valenti and Kelly Altmann

In addition, it also touched on the major issues surrounding state Medicaid plan programs, specifically:

The inability to assess standards and success among states

Even though the federal government requires states to establish quality standards for Medicaid programs and monitor quality and reporting compliance, there is practically no uniformity for these standards across the states. Shortfalls in contract requirements and data collection make it difficult to compare state-to-state data and assess whether beneficiary health has actually improved throughout the country.

Staff cuts and questions of accountability

Some states have cut back on staffing of their Medicaid offices. This not only raises concerns about the states’ ability to hold health plans accountable, but also has resulted in the federal government being criticized for failing to ensure the states properly oversee the plans.

Inconsistencies in practices

States are required to set rates, monitor contracts and enrollment practices, and oversee operational functions and compliance programs of their Medicaid plans, but how each state complies differs. This, unfortunately, leads to operational and reporting inconsistencies and prevents the ability to share and compare best practices, data and other important information.

Lack of CMS state oversight

Each state is required to audit health plans providing Medicaid services. CMS monitors that state oversight. However, CMS has been accused of having problems with such oversight, according to reports from the Department of Health and Human Services Inspector General’s office and the U.S. Government Accountability Office.

To alleviate these challenges, CMS is moving to exert more direct control and oversight of these programs, which will ultimately benefit Medicaid plans. However, preparing compliance efforts will be key. To find out how Medicaid plans can prepare for increased CMS oversight, see our previous blog post on this topic.

We excel in providing consulting and software solutions to help government-sponsored health plans significantly mitigate compliance risk. If you’d like to learn more, please contact us today.

At this stage of the game, tension is running high. By now, many health plans have likely discovered the way they were planning on creating the documents won’t work, have encountered issues with vendors, or any other number of challenges that put tasks and timelines into a tailspin.

This follow-up piece provides advice for how to push through bottlenecks, solve last-minute challenges and get compliant AEP materials out accurately and on time.

1.     Address Critical Timeline Challenges Immediately

If any tasks on your timeline are slipping, focus on addressing the critical missed deadlines as quickly as possible. If your team was having meetings once a week, now is the time to increase meeting frequency to twice a week, or as often as necessary. In addition, the marketing communications team should communicate daily, keep management abreast of the status of projects, and stay alert for possible roadblocks that may delay progress.

2.     Effectively Manage Subject Matter Experts

When working with a health plan’s internal subject matter experts (SMEs), marketing communications directors should clearly express their needs and anticipate what would be helpful for SMEs to know in advance. For example, educating SMEs on potential compliance issues that may arise while they are preparing content for the documents will help increase the likelihood that they provide usable content the first time around. Giving SMEs explicit deadlines when you request information will also ensure timelines are maintained.

3.   Keep Notes to Document the Good, Bad and Ugly

Inevitably, you will have moments during the AEP materials creation process when you have ideas for how to do things differently next year. Even though it may be difficult, try to keep notes about what’s working and what’s not working that you can reference later, with the ultimate goal being to make your life easier the next time around. After the AEP season concludes, review your notes, identify your weak spots, and consider what tools and resources – such as CodySoft – may be worthwhile to improve the AEP materials creation process for 2016.

Medicare plans must create, print and deliver AEP materials, specifically, Annual Notification of Change (ANOCs) and Evidence of Coverage (EOCs), to members by September 30. Preparing AEP materials can be a time-consuming, labor-intensive process and wrought with compliance risk.

1. Create a Comprehensive Task List and Timeline

Numerous tasks and various departments and people are involved in creating AEP materials from start to finish. Having a well-thought-out production timeline will help ensure your materials are completed on time and are compliant. Consider using a program, such as CodySoft, that allows you to assign tasks, people and deadlines to ensure streamlined project management, as this can make the job infinitely easier.

2. Use the 2015 Model Documents

Some health plans may be tempted to create their 2015 AEP materials by making updates to their 2014 templates. However, if one data point of the thousands you update is missed, your health plan is out of compliance. Using the 2015 model documents provided by CMS – which only requires a 10-day file and use approval period – is the least risky and most expeditious way to prepare your AEP materials.

3. Use a “Central Source of Truth” Data Grid for All Plan Benefit Information

Plan benefit information that must be included in members’ ANOCs, EOCs and Summary of Benefits (SB) could have variables that number in the tens of thousands. With such a large number of data elements to manage, plans must use one “central source of truth” for benefit information if they expect to meet CMS’s requirements. A tool like CodySoft will help automate this process and ensure CMS compliance.