In 2018, The Centers for Medicare & Medicaid Services (CMS) announced regulatory changes that impacted how and when health plans must provide Evidence of Coverage (EOC) documents to members. Uncoupling the EOC from the Annual Notice of Change (ANOC) document mailing, allowing for electronic delivery of the EOC and extending the EOC delivery deadline to October 15 brought relief to health plans nationwide.

However, because plans now have more time and flexibility in delivering the EOCs, CMS will be exercising even more rigorous oversight of these documents and other member communications. Here are five areas we expect CMS to be scrutinizing more heavily in 2019.

1. 508 Remediation
With the new ANOC rules around providing member access to plan year EOCs on plan websites instead of print and mail, CMS will likely be looking at plan websites more closely for Section 508 compliance (accessibility) issues.

2. Website navigation and ease of access to member-specific documents
CMS will likely be assessing whether members were able to easily navigate, access and download their correct plan EOCs in 2018/2019, and may write rules around how and where PDFs must be located on plan websites to allow for specificity and ease of access.

If CMS or plans find that members’ experience with navigating and accessing these documents proves to be less than desired, plans may want to (or have to) deploy a secure portal containing only the specific member’s plan documents. This may also include maintaining member preference and email capabilities that tie back to the secure member portal.

3. Member Communications Opt-In/Opt-Out Preferences
With increasing responsibility for monitoring and managing members’ opt-in/opt-out preference for digital vs. printed materials over the entire lifecycle of enrollment, plans will need to assess and augment member communications processes and protocols to ensure that member records are appended with this preference data and kept up to date.

4. Provider Data
Increased scrutiny and responsibility are being put on plans to ensure provider data is up to date and accurate; however, maintaining this large data set is highly problematic and time-intensive. Plans may need to look to third-party data managers and consolidators for provider data management and validation. There are a number of vendors that perform this function for plans that don’t want to shoulder the cost or don’t have the infrastructure to keep provider listings up to date.

5. Member Requests for Print Materials
A decrease in CMS requirements for print and fulfillment of marketing materials is logically accompanied by an increase in the number of daily member requests (opt-in) to printed copies of these materials. Turnaround times for fulfilling member-requested marketing materials are being monitored closely. Therefore, plans will need to carefully refine internal processes for capturing requests and processing data, plus ensure seamless integration with print and fulfillment FDRs.

As the scope for fulfilling member-requested print materials expands, plans will need to partner with industry-savvy print and fulfillment FDRs that have highly efficient and expandable on-demand print and fulfillment capabilities in order to meet accuracy, timeliness and auditability targets.

Our team of experts at CODY and our CodySoft products can help your plan adjust to CMS’s expectations in 2019. Contact us today for a consultation or software demo.

By: Doug Pray