September 30th has long passed, but now is the time to reflect on your ANOC/EOC fulfillment processes in order to implement new efficiencies for next year. As a full-service member communications management company, we take pride in keeping our clients informed of new regulatory change, especially when it can be converted into new savings. With that in mind, below are several key changes that were included in the 2018 Medicare Marketing Guidelines (MMG). If you were unable to fully address these changes this year due to the late release of the MMG, we highly advise evaluating how you can for next year.

New Formulary Flexibility

According to 60.4.3 of the MMG 2018, plans can now either:

a. Send enrollees a hard copy of the full or abridged formulary at the time of enrollment and annually, either attached to the EOC or mailed separately.
b. Send a hard copy notice describing where enrollees can find the online formulary and how to request a hard copy. This notice must be a stand-alone document (i.e., not bound with other materials) and may be included in the same mailing envelope as the (ANOC/EOC).

If the plan will allow requests for a hard copy by email, then they must communicate the following:

“If you have a question about covered drugs, please call [customer service phone #] or visit [URL] to access our online formulary. If you would like a formulary mailed to you, you may call the number above, request one at the website link provided above, or email [Part D Sponsor email address].”

If the plan does not wish to allow for requests for hard copies via email, then they must communicate the following:

“If you have a question about covered drugs, please call [customer service phone #] or visit [URL] to access our online formulary. If you would like a formulary mailed to you, you may call the number above, request one at the website link provided above, or email [Part D Sponsor email address].”

With most plans already including a notice of how to access electronic versions of the provider directory/pharmacy directory in their ANOC/EOC’s, content about how to access one’s formulary and request hard copies can simply be added to the directory notice as a combined piece. Plans that were unable to integrate this notice or secure the print-on-demand capabilities needed to support the fulfillment of small-volume orders should ensure that they have solutions in place for next year in order to take advantage of the savings. In addition, directing members to an email address for the submission of hard copy requests may not be the most efficient method. We strongly advise integrating a form onto your website or on a standalone landing page/micro site connected to a production order management database.

Email as a Marketing Channel

According to 70.1 of the MMG 2018, “A Plan/Part D Sponsor may initiate separate electronic contact. Plans/Part D Sponsors must provide an opt-out process to no longer receive electronic communications.“

This new permission means that Medicare marketers can now email prospects, so long as there is an unsubscribe option and the proper disclaimers are included. This translates into not only more personalized and consistent outreach opportunity, but also more savings in being able to minimize direct mail volume. With email now a viable pre-sale marketing channel, Medicare Advantage marketers should be diligently working to build segmented prospect email lists while identifying an email software provider that can support both high-level personalization as well as high-level data security and engagement reporting.

Householding Now Allowed

For the first time, plans can send a single copy of enrollment materials (all materials noted in section 30.7) to a household of multiple members receiving the same plan coverage, with the obvious exception of member ID cards. According to section 30.7.1 of the MMG 2018, the following criteria must be met in order to permit householding:

1. The recipients are enrolled into the same plan (i.e., have the same contract and PBP number).
2. The recipients have the same address.
3. There is reasonable assurance that the individuals are related (e.g., they have the same last name) or have otherwise received consent from the recipients if they are.

MA plans should not take any shortcuts in documenting their criteria for “reasonable assurance” though. Plans that were unable to get the data together this year to support householding should consider identifying a new fulfillment partner for next year that offers comprehensive data list processing and householding services in order to reap the print savings next year.

15-Day Input of ANOC/EOC Mail Dates

ANOC/EOC material must be inputted with the actual mail dates into HPMS within 15 days of mailing the material. This means having real-time reporting in place for the mail distribution of ANOC/EOCs that is viewable at the individual member level and that can easily be exported into HPMS.

We make it easy for our clients to meet this mandate by offering an application that real-time reports on ANOC/EOC status at the point of file receipt, production, fulfillment, distribution and mail delivery—all searchable by member ID. If you’re current vendor does not offer granular-level mail distribution tracking, then perhaps it’s time to consider one who does or a reporting system that can integrate with your existing workflows.

The ability to migrate formularies to print-on-demand, e-market to MA prospects, and integrate householding offers tremendous savings and workflow efficiencies for the MA plans able to execute. If you’re struggling to achieve any of the following with your current vendors, please contact us and one of our consultants would be happy to outline custom implementation strategies for your programs.

Please call 203-731-3555 or email inquiries@cierant.com to explore how you can achieve a more cost-effective and compliant ANOC/EOC process next year.