The Model Documents released by CMS each year offer instructional guidance and standardized document templates for the member materials that must be distributed each fall by Medicare Advantage, Medicare Advantage Prescription Drug, Prescription Drug, and 1876 Cost Plans. On July 24th, the 2019 ANOC and EOC Standardized Models were released, which reinforce the new policies of the Final Caller Letter and “Patients Over Paperwork Initiative,” which state that the Annual Notice of Change (ANOC) and the Evidence of Coverage (EOC) are to become two independent documents with different delivery requirements and more flexible reporting standards.

Despite these new flexibilities, the standardized models are to be used by MAOs, PDPs and section 1876 Cost Plans exactly as provided, with only minor edit alterations permitted, such as updating phone numbers and reference names, adding plan logo, and renumbering chapters and sections as needed. Supplementing the model documents are the 2019 ANOC and EOC Instructions, which offer specific guidance on how to compose, assemble, submit, and report on the ANOC and EOC in accordance with the new mailing schedule and other key changes.

September 30th: ANOC Delivery Date

All Plans/Part D Sponsors must mail the standalone ANOC for member receipt by September 30th.

CMS strongly encourages plans to send the LIS Rider in the same envelope as the ANOC. Other items that should also be included in the envelope are a driver/carrier sheet, Multi Language Insert ( MLI) and Non-Disclosure Notice (NDN). Another item that plans have begun to include with the ANOC is the notice required for electronic delivery of provider directory/pharmacy directories and formularies (PPD/Formulary Notice), in place of a hard copy directory and formulary. CMS advises that this notice be adapted to include notification of electronic EOC delivery for the plans electing to offer this option; however, a separate EOC Notice is also acceptable.  Similar to e-delivery of directories and formularies,  you must be ready to fulfill requests for hard copy EOCs within three business days of the member’s request, which means getting print-on-demand with one-day fulfillment in place.

CMS also permits the Summary of Benefits be included with the ANOC, although many plans include the SOB in their pre-sale kits. D-SNPS are no longer required to mail the Summary of Benefits with the ANOC, but may do so.

This means that a fully cost-optimized 2019 ANOC mailing should include the following components:

• Driver Sheet
• ANOC Cover Letter
• ANOC book
• LIS Rider
• PPD/Formulary/EOC Notice (“The Notice”)
• Notice of Privacy Practices
• Multi Language Insert
• Opt-In Form: Form to opt-in to receive upcoming ANOC and EOC via email

While many plans already have an established BRC or notice for directories, the next step is evolving this piece to include the EOC and formulary, and setting up the online request forms to support.

In addition, plans must continue to adhere to the 10-day compliance rule. This means that all AEP enrollees must receive both the ANOC and EOC within ten calendar days from receipt of CMS confirmation of enrollment – or by the last day of the month prior to the plan effective date – whichever date comes later.

October 15th: EOC Delivery Date

All Plans/Part D Sponsors must provide the EOC to enrollees, either by mailing a hard copy or providing electroncially, by no later than October 15th. Plans also have the option of sending a hard copy EOC with the ANOC, though not advised, as the goal of separating the pieces is to allow members to better focus on plan changes in advance of AEP.

Should plans choose to deliver the EOC electronically, they must provide a Notice within the ANOC maiing. The Notice must include the following information:

• Notification that the electronic EOC will be available by October 15, 2018
• Instruction on how to access the electronic EOC (e.g. URL address)
• Instruction on how to request a hard copy (e.g. phone number, online link)

As mentioned, this Notice can be combined with the directory/formulary notice and should be mailed with the ANOC to reduce mailing costs and beneficiary confusion.

Once plans have submitted their model ANOC and EOC documents for each offered plan benefit package to HPMS, they may begin distribution. As is process, all plans must input the actual mail dates (AMDs) for ANOC into HPMS within 15 days of mailing.

Additional Reminders:

• Multiple benefits coverage can be included in a singular EOC, but they must be benefit packages for the same plan type and all either offer, or not offer, Part D coverage. Each package must be clearly distinguished from the other.
• Plans may not combine multiple benefit packages in one ANOC. Each ANOC must be specific to an enrollee’s plan.
• Plans sending EOCs to new enrollees with effective dates of January 1 or later should edit the EOC to remove all references to the ANOC.
• Other than providing the SB with the ANOC, plans may not highlight benefits or information regarding upcoming 2019 plan activities in the ANOC, the EOC, or the Notice.
• Business Reply Cards that do not mention plan-specific benefits do not need to be submitted into HPMS.
• The EOC Notice must be zipped with the EOC in HPMS.

While we will be releasing a comprehensive analysis of the 2019 Medicare Communication and Marketing Guidelines within the next few days to further drive the development of your 2019 marketing strategies, should you require consultation or direct support in reconstructing your ANOC and EOC composition, production or distribution processes to adapt to these new requirements, please call 203-731-3555 or email inquires@cierant.com. From personalized composition to high-speed print-on-demand and secure e-delivery, we offer the services needed to make the shift to EOC e-delivery seamless.