CMS Skips Another Year on the MCMG

Health plans are wondering “where are my updated Medicare Communications and Marketing Guidelines (MCMG)?”

For the second consecutive year, the Centers for Medicare & Medicaid Services (CMS) stated that there will be no updated MCMG for CY2021. Instead, plans are instructed to use the existing MCMG and related memos from CY2020. How will changes be communicated to plans? How will plans manage this information?

The MCMG is a comprehensive document that CMS generally distributes to plans every year outlining its guidance for the upcoming year. But even though there are no new guidelines, as CODY CEO Deb Mabari states: “Health plans are still responsible for the information that most likely will be provided through HPMS memos.” These memos are released almost daily and contain information on a broad variety of topics. This year it is essential for plans to have a system to better manage and route ALL HPMS Memos, especially now that we know CMS will be peppering MCMG guidance into these memos.”

It always has been and will continue to be the health plans’ responsibility to monitor and respond to all HPMS memos and implement any required actions from the memos. This process is labor-intensive and prone to errors of omission if the distribution and response workflow is not robust and thorough. It’s easy to miss a memo that may require immediate or future action on the part of one or more people or departments at a plan. The consequences may be dire. Failing to make a required change could result in member confusion and beneficiary impact, as well as fines, sanctions or a shut down by CMS.

The year 2020 will be a challenging one for health plans as they try to manage their CY2021 AEP.

In addition, to be in keeping with CMS audit protocols, “Plans need to be able to describe how CMS Medicare regulations, requirements and interpretive guidance (e.g. HPMS guidance memoranda) are disseminated to the appropriate Medicare functions for implementation and quality control measures to confirm appropriate and timely implementation.”

Here are some tips that have worked for our clients when CMS throws a curveball like not providing a new version of a chapter:

  • Being able to count on a system such as the HPMS Memo Module® not only helps support your team, but also maximizes efficiency and minimizes compliance risk
  • In the event of a CMS audit, you’ll be prepared to locate and provide proof of compliance easily
  • A centralized system gives you the ability to streamline the review, organization, and response process while providing documented proof to internal constituents and external regulators that your memos have been distributed and read
  • In addition to robust reporting tools to track internal acknowledgements, you’ll reduce administrative costs related to manual review

If your health plan struggles to keep up with the volume of HPMS Memos requiring action, please contact us today to learn how CODY’s HPMS Memo Module® can help automate your process, reduce stress, and enhance your Compliance Program.

About CODY: CODY works with more than 60 government-funded, commercial and ACA health plans across 45 states and Puerto Rico. We help health plans maximize efficiencies and strategically integrate operations by streamlining marketing communications and improving regulatory compliance. Our proprietary suite of software, CodySoft®, is specifically designed for health plans.