Navigating the CMS Requirements for Medicare Advantage Plans in the Wake of COVID-19
One of the great aspects of getting to work with Medicare Advantage Plans in all 50 States and U.S. territories is hearing about the unique challenges they face based not only on their individual membership size but on how they interpret the various regulations outlined by the Centers for Medicare & Medicaid Services (CMS). What has been particularly interesting during the wake of COVID-19 is how plans across the country have had to not only comply and interpret the changing measures outlined by CMS but juggle that with the guidance governed by their individual States. This combined with the fact plans are servicing the most at risk demographic has caused a significant amount of unknowns in the managed care industry as leadership teams in the Medicare Advantage (MA) space try to navigate for lack of a better term the “New Normal”.
After having had several conversations with our client leadership teams in the MA space across the country with membership sizes ranging from 2,000 up to 49 million each plan has offered their unique perspective on the challenges they have faced. Outlined below are a few of those challenge areas along with steps they have taken to mediate risk both in remaining HIPAA and PHI compliant while keeping their members and business healthy in the wake of COVID-19.
To start, COVID-19 hit the U.S. during one of the most crucial timeframes of the year in the industry, CMS Secret Shopper Period. As the telephonic interpretation provider for a vast majority of plans in the space we would often have weekly touch points with our plans to ensure audit readiness on the language services side knowing any one missed call could result in a decrease in STARS. What we soon realized through our discussions was that as plans started moving their customer advocate representatives to work at home there was going to be heavier reliance on 3rd party vendor partners to ensure not only a seamless transition of services but that proper security measures were being met to ensure HIPAA and PHI compliance. Many MA contact centers for example started using voice authentication for workers to remote in to their work from home stations. Others distributed secure company laptops with webcam accessibility to monitor the work space in real time. Some plans even modified shifts within their contact centers for individuals lacking the proper technology at their homes to ensure no member or CMS calls were missed.
As it turns out most of the leaders in the Managed Care space we have spoken with now maintain in the wake of the pandemic that CMS will be using last year’s STAR scores as the benchmark for AEP 2021. This means that Medicare Advantage Plans who did not fare as well as they would have liked on their scores last year will need to think of creative ways to prospect to new members while ensuring they have processes in place for next audit period.
As a First Tier Downstream Entity (FDR) TransPerfect has mirrored what many of our clients have done to ensure business continuity within the contact centers during the wake of COVID-19. There will also likely be larger audits to ensure compliance moving in to CMS Secret Shopper season next February. As it was seen this year despite the pandemic CMS did not relent on interpreter service calls so we are certain this will be the case on all their measurements next year.
So what will the Medicare Advantage market look like in the wake of COVID-19 moving in to Annual Enrollment Period for 2021? It likely through our discussions with MA plans that CMS will be implementing a strict policy of no in person broker meetings and seminars offering a unique challenge for plans to gain prospective members. While traditionally Sales teams have met with prospective members in gathering spots like town halls, churches and good old fashion door to door meetings they will now have to rely on technology that is dependable and easy for senior populations to use.
Through our conversations with plans like Blue Cross Blue Shield Brokers are making innovations through the creation of 2-3 minute short videos describing the benefits to members. Others are taking on outbound call campaigns in the top 3-5 languages they service with in their country or municipality to better reach members. Other plans are taking more technologically savvy measures by implementing speech to text signatures to onboard members telephonically which have thus far deemed not only successful but compliant with CMS.
COVID-19 has shaken up a vast majority of industries and in my opinion healthcare the most. With aspects ranging from security and infrastructure to member acquisition who are most susceptible to complications with the virus it will be interesting to see what plans are doing to provide the best coverage while remaining complaint with HIPAA and CMS.
Additionally we look forward to seeing what other innovations come about in the wake of the pandemic and as the largest technology and language services firm in the managed care space are keen in hearing more about how we can help. If you are Interested in finding unique ways to reach prospective members through video creation, speech to text, and Contact Center Support or you are in need of translation and remediation of your vital CMS materials this upcoming enrollment period reach out to healthcare@transperfect.com.
Our team of Managed Care experts are on standby and ready to help you navigate the requirements outlined by CMS while working with you to find creative ways to reach your members during the wake of COVID-19.
