CMS: Marketplace Agent and Broker Open Enrollment Office Hours

CMS will hold an informational session regarding Marketplace operations that may impact agents and brokers who are providing enrollment assistance to consumers. There will also be an open forum for participants to ask questions and share their observations from the Open Enrollment period.

DATE: Monday, November 25, 2019

TIME: 2:30 pm–3:30 pm

Register.

EMPLOYER ACTION REQUIRED: Distribute Medicare Part D Notices by October 15

Group health plan sponsors must provide Medicare Part D “creditable coverage” notices prior to October 15, 2019, the start date of the Medicare annual enrollment period for Part D, Prescription Drug coverage (open enrollment runs from October 15 to December 7, 2019).

Most plan sponsors use the Model Medicare Part D Notices provided by the Centers for Medicare and Medicaid Services (CMS) to notify affected plan participants. Links to all the model letters (in English and Spanish) are available here in .pdf format. Cornerstone has provided versions of the notice in Word Document format for your convenience.

Creditable Coverage Notice

Non-Creditable Coverage Notice

The carriers plan listings and/or links to their creditable coverage site are available below:

Aetna: Please contact your Broker Advisor for more information.

Anthem: Click here.

Humana: Click here.

UnitedHealthcare: Click here.

Medical Mutual: COSE requested. All other plans, click here.

The October 15 deadline applies for all group health plan sponsors, regardless of plan year, plan size, employer size, grandfather status, or whether the plan is insured or self-funded.

Employers who send out Open Enrollment packets prior to October 15 often include the Medicare Part D notices in the Open Enrollment packets to avoid the extra cost and administrative burden of sending them separately.

Because these notices have not changed since 2018, employers who provided these notices earlier this year are not required to provide them again.

Employers are also required to notify CMS online annually that they have sent out these Part D notices. The notice to CMS is due within 60 days after the start of the plan year. See the last paragraph of this article for details.

When Is the Medicare Part D Notice Required?

Medicare Part D notices must be provided at least once annually, prior to October 15th, which is the beginning of the Part D annual enrollment period. Additional notices must be provided if the employer-provided coverage changes (from creditable to non-creditable, or vice-versa), if the individual requests a copy of the notice, and when an individual first enrolls in the employer plan.

Why is the Part D Notice Required?

The reason plan sponsors are required to provide Part D Notices is because a penalty will be imposed on an individual if he/she, after becoming eligible for Medicare Part D coverage, has a lapse of “creditable” prescription drug coverage for a period of at least 63 days. Additionally, such individuals may have to wait until the following October to join. An individual can elect either Medicare prescription drug coverage or other “creditable coverage” to avoid having a lapse in coverage. Thus, Medicare-eligible participants in employer group health plans must know whether or not the employer group coverage is “creditable” so they do not unwittingly incur a late enrollment penalty.

Additional Details on the Disclosure Requirements

  • Group health plan sponsors to whom this disclosure requirement applies include employers and Unions; multiple employer welfare arrangements (MEWAs); federal, state and local government employers; and churches.
  • The Part D Notice must be provided not only to Medicare-eligible active working employees and their dependents, but also to participants who are retired, on COBRA, or disabled and covered under the employer’s prescription drug plan.
  • Although the requirement is only that “Medicare-eligible” individuals be provided this notice, employers often provide it to all plan participants and dependents, because of the practical difficulty of knowing who is Medicare-eligible.

Annual Notice to CMS Also required, though not by October 15th

Additionally, plan sponsors are required to notify CMS annually, via the CMS website (Online Disclosure to CMS form). This notice must be made within 60 days after the beginning of the plan year (or contract renewal date, for small plans that do not file Form 5500s so do not specify a plan year), and it pertains to the creditable coverage status for the prior plan year. For calendar year plans, this notice must be provided to CMS no later than March 1.  Sponsors of non-calendar year plans should mark their calendars to make sure the disclosure to CMS is made within 60 days after the beginning of the plan year. (E.g., for an April 1 plan year, the CMS online disclosure should be made no later than May 30.)

Additionally, if applicable, plan sponsors must complete the Online Disclosure to CMS Form within 30 days after termination of a prescription drug plan or within 30 days after any change in creditable coverage status.

For additional information, click here for the main CMS webpage that provides guidance on “creditable coverage.” Or you can visit the web page at https://www.cms.gov/Medicare/Prescription-Drug-Coverage/CreditableCoverage/

CMS Extends Transitional Relief Until January 1, 2021

The Centers for Medicare & Medicaid Services (CMS) recently released a bulletin extending non-enforcement policies against certain non-ACA-compliant non-grandfathered health insurance coverage in the small group and individual markets.

The extended transitional policy in this bulletin applies for policy years beginning on or before October 1, 2020, provided that all such coverage comes into compliance with the specified requirements by January 1, 2021.

Click here to read the full release from CMS.

Questions? Contact your Cornerstone representative for additional information.

CMS Releases Proposed Rule to Safeguard Taxpayer Dollars

The Centers for Medicare and Medicaid Services (CMS) recently issued a proposed rule that advocates for additional oversight to protect both the issuer and consumer. The rule, called the “Patient Protection and Affordable Care Act (PPACA): Exchange Program Integrity”, would safeguard taxpayer dollars by ensuring that people are accurately determined eligible for premium subsidies they receive through the Exchange.

Click here to read the full release.

View the fact sheet from CMS.

View the proposed rule.

CMS’s New Registration Tracker is Now Available

Last month, the Centers for Medicare & Medicaid Services (CMS) launched a new tool that enables you to look up your Marketplace registration status using your National Producer Number (NPN) and ZIP Code.

The tool shows you a summary of your Marketplace registration status.

In addition, the tool displays details of the Marketplace training and registration steps you have completed.

It also shows the status of CMS’ validation of the NPN you provided in your Marketplace Learning Management System (MLMS) profile.

Trump Administration Releases Final Rule and Fact Sheet Regarding Short-Term Limited Duration Insurance

The Trump Administration issued a final rule Wednesday morning regarding short-term plans (or STPs) that is expected to go into effect 60 days from today. The rule will end a policy from the Obama Administration that restricted the length of time for STPs. The final rule restores the maximum duration of STPs to up to 364 days, with the ability to renew for up to 36 months at the carrier’s discretion.

The rule was created in response to an executive order passed by President Trump in October that directed federal agencies to expand the availability of Association Health Plans, short-term policies, and HRAs.

Click here to view the final rule.

Click here to view the fact sheet.

 

Contact your Cornerstone representative for any additional details.

CMS Mailing New Medicare Cards to Wave 4 States

The Centers for Medicare and Medicaid Services started mailing new Medicare cards to people with Medicare who live in Wave 4 states: Connecticut, Maine, Massachusetts, New Hampshire, New Jersey, New York, Rhode Island, and Vermont. CMS will continue to mail new cards to people who live in Wave 3 states, as well as nationwide to people who are new to Medicare.

CMS finished mailing cards to people with Medicare who live in Wave 1 and Wave 2 states and territories (Alaska, American Samoa, California, Delaware, District of Columbia, Guam, Hawaii, Maryland, Northern Mariana Islands, Pennsylvania, Oregon, Virginia, and West Virginia). If someone with Medicare says they did not get a card, print and give them the “Still Waiting for Your New Card?” handout (in English or Spanish) or instruct them to:

  • Sign into MyMedicare.gov to see if we mailed their card. If so, they can print an official card. They need to create an account if they do not already have one
  • Call 1-800-MEDICARE (1-800-633-4227). There might be something that needs to be corrected, such as updating their mailing address.

via Medicare Learning Network

CMS Releases Exchanges Trends Report

CMS recently released a report outlining the current condition of the operational and programmatic
aspects of the Exchanges.

Key Highlights:

  • For plan year 2018, 49,100 agents and brokers registered with Federal platform Exchanges, supporting 42 percent of overall enrollments.
  • The cost breakdown for registration/training, technical assistance, and oversight is $2.40 per enrollee.
  • The biggest concerns for agents and brokers are lack of competition in the individual market and availability of commissions from insurance carriers.
  • To date, CMS has implemented 93 percent of recommendations from our agent and broker partners

Click here to view the full Trend Report from CMS.

CMS to Suspend ACA Risk-Adjustment Payments

The Centers for Medicare & Medicaid Services announced that a months-old federal court ruling will force it to suspend risk-adjustment payments, worth about $10.4 billion for 2017. These payments are meant to help balance the insurance markets when some insurers had to take on sicker, more costly patients.

 

For more information, click here.