CMS End-of-Year (EOY) Low-Income-Subsidy (LIS) Activities—Is Your Health Plan Up to Date?

Hopefully, you are off to a successful AEP! To keep the momentum going, here’s some valuable information and best practices regarding EOY activities, including the Low-Income Subsidy (LIS)/Reassignment process. Is your staff well-versed in these activities? Are your systems ready to accept CMS’ year-end files? If not, read on to learn more!

As referenced in the “End-of-Year 2022 Enrollment and Payment Systems Processing Information”, these EOY activities are critical operations to ensure a seamless transition to 2023. A thorough understanding of the guidance, data, and implementation strategy is key to preparing your organization for the upcoming EOY activities. Furthermore, preparedness and timely processing will create a positive member experience, especially for prescription drug point-of-sale purchases. Let’s dive into how you can best prepare.

Loss of Low-Income Subsidy (LIS) Data Files 

CMS sends two “Loss of LIS data files” to Plan Sponsors each fall.

• The first file, sent in October, identified members who no longer have LIS as of January 1, 2023. The first file is informational only and is used to assist Plans in contacting the affected population and encouraging them to file an application to requalify for LIS in the upcoming calendar year.
  • CMS expects Plan Sponsors to contact, by phone or mail, every member who will no longer qualify automatically for LIS beginning in 2023 to encourage them to apply for Extra Help and to assist them through the process. The HPMS memorandum titled “Re-Determination of Part D Low-Income Subsidy Eligibility for 2023”, issued on July 1, 2022, contains additional information on this process.
• The second file, to be sent in mid-December, is an updated version of the October file, indicating those beneficiaries who still no longer have the LIS as of January 1, 2023. The file format can be found in the PCUG §4.4.3. This file should be processed through normal plan LIS processes.

EOY Processing Timeline

• 11/01/2022:
  • Plans will receive Special Transaction Reply Reports (STRR) and other reports containing reassignment activity and reassignment letters sent to beneficiaries.
• 11/02/2022 – 11/03/2022:
  • CMS conducts CMS-generated rollover processing
• 11/02/2022 – 11/10/2022:
  • MARx UI will be in a read-only mode
• 11/04/2022:
  • CMS will place all batch files that MARx received after this November plan data due date into a holding status. These files will be held until the 2023 payment configuration tasks are complete. CMS will begin to process the files in the order received beginning on or about November 10, 2022. Plans can also expect to begin receiving their Daily Transaction Reply Reports at that time.
• 11/07/2022:
  • Transactions 75 and 78, with an effective date of January 1, 2023, will not be processed if submitted before this date.
    • This may cause an increase in Billing and LEP TRCs.
  • 11/10/2022:
    • Plans can expect to begin receiving the Daily Transaction Reply Reports (DTRR) with transactions held after November 4th.

Reassignment

Each year, CMS reassigns low-income beneficiaries from PDPs that are going above the regional LIS benchmark (and did not or could not waive a de minimis amount of premium above the benchmark), and from PDPs and MA plans that are terminating (which includes MA plans that are reducing their service areas). Reference the “2023 Reassignment of Low-Income Subsidy Beneficiaries in Non-Renewing Medicare Advantage Plans and Medicare Advantage Plans Reducing their Service Areas” for details surrounding the reassignment process.

CMS will only reassign individuals who meet the following criteria: 

• Are LIS-eligible in 2022 and will remain LIS-eligible in 2023; and
• Are enrolled in an MA plan that will be non-renewing or has a service area reduction (SAR), unless the plan is an MA Private Fee-for-Service plan, and the individual already has concomitant enrollment in a stand-alone PDP that is not affected by PDP premium increase reassignment for 2023.

CMS will notify gaining and losing PDPs by Special Transaction Reply Report (STRR):

• Within 10 calendar days of receipt of the STRR showing reassignment, gaining PDPs must send beneficiaries confirmation that their enrollment has been accepted by CMS (See Exhibit 29 of Chapter 3).
• Within 10 calendar days of receipt of the STRR showing reassignment, losing PDPs must send beneficiaries confirmation of disenrollment due to reassignment (See Exhibit 10b of Chapter 3).

Finally, the 2023 payment/premium configurations will be processed between November 7 and November 10, 2022. After configurations are established, the Part C Premium/PPO transactions will be processed.

• No Premiums Due 
  • For enrollees who may have been inadvertently put into a “No Premium Due” status, the “No Premium Due Data File” should be made available during the second full week of November. Plans should wait until then before submitting transactions for those enrollees.
  • If the Part C premium amount is composed only of elected optional supplemental benefits, and no Part D premium is due, plans should also review the “No Premium Due Data File” to identify enrollees who may have been changed to a “No Premium Due” status.

We’re Here to Help  

To avoid CTMs, access to care issues, and reconciliation discrepancies, begin forming a strategy for your EOY processing now. If you need assistance during this process and throughout the year, contact us today for a consultation or a software demo.

About us: CODY^® has worked with over 70 government-funded, commercial, and ACA health plans across 50 states and Puerto Rico. We help align internal operations with CMS guidelines to improve regulatory compliance, maximize performance, and streamline member/provider communications across the enterprise. CodySoft^® and Membership Suite^™™, our proprietary suites of software, are designed specifically for health plans. www.codyconsulting.com