Humana would like to share new information that we believe agents will find particularly useful as you prepare to start your marketing efforts for the 2014 AEP.
1. The first piece of information is about some VERY important news from CMS about a brand new requirement of plan sponsors this year. CMS is requiring that plan sponsors conduct an investigation of any applications where any agent or broker involvement is indicated when that application was received before the official start of the enrollment period (Oct. 15th) to identify instances of "solicitation" by agents in violation of CMS rules.
2. Secondly, we are sharing a new marketing piece Humana has created called "Benefits-at-a-Glance" and how it should be used. This document provides a simple one page summary in an easy to compare format of Humana plans so you can help your client compare plan options. How you use this tool is important to keep in mind though, because it doesn't replace the CMS-required documents we must share with our enrollees.
3. Lastly, we're reminding you of the importance of telling people about the Multi-language insert and where to find it in our documents.
1. Pre-AEP Application Guidance
As we fast approach the Pre-AEP period between October 1st and October 14th, it is important to note that there are some very specific and important application handling guidelines that ALL agents must follow in order to stay compliant. Please read these guidelines very carefully, as they will help you navigate the Pre-AEP waters compliantly.
During Pre-AEP, agents are allowed to meet with beneficiaries, assess their needs, review plan changes and options, give a full product presentation, and make recommendations on coverage that will best meet beneficiaries' needs over the next year. One of the most important things to remember during Pre-AEP is that while agents can assist a beneficiary in completing a paper application they cannot encourage completion, solicit, accept, take possession of, or "just hold on to" any applications for the 2014 contract year prior to AEP, October 15, 2013. Agents should instruct the beneficiary that they want to enroll in our plan, they should sign, date and mail in the application for receipt by Humana once AEP has started on October 15th.
New CMS Guidance!
New CMS enrollment guidance has been issued this year that demonstrates CMS concerted efforts to curtail agent-solicited applications during the pre-AEP period. In Chapter 2 & 3 it states:
"Paper AEP enrollment requests received prior to the start of the AEP for which there is indication of sales agent or broker involvement in the submission of the request (i.e., the name or contact information of a sales agent or broker) must be investigated by the organization for compliance with the requirements in the Medicare Marketing Guidelines."
This means that Humana must investigate any application that it receives prior to October 15, 2013 that has an agent's name on it. As a result, it is EXTREMELY important to reinforce to enrollees that the application should NOT be sent to Humana before October 15. Humana will be conducting an investigation for any paper application received by mail through October 15, 2013 (paper applications received on the 15th had to have been mailed/collected prior to the 15th). In instances where an agent is suspected of accepting and/or mailing an application, further investigation will be made with appropriate corrective action. Founded allegations where an agent collected or solicited pre-AEP applications in the past have resulted in agent termination. Previous guidance from Sales Integrity indicated that agents should inform the enrollee to mail the application so that Humana receives it on or around October 15. This may have resulted in applications being received inadvertently prior to AEP. In order to avoid agent investigations going forward, we are changing this guidance. Agents should now direct enrollees to mail the application ON October 15th to ensure that the application is received during AEP.
Important Pre-AEP Reminders
- No advertising of 2014 AEP or marketing of 2014 plan benefits may begin until October 1st.
- An agent may give a full disclosure presentation using the 2014 sales presentation and summary of benefits beginning October 1, 2013.
- An agent may assist a prospect in completing a 2014 paper enrollment application beginning October 1, 2013. The agent should place his/her name and SAN on the application, but the agent should NOT date the application. A signature date by the agent name would signify Humana taking possession of the application. Therefore, during Pre-AEP it is critical that you DO NOT date the application.
- Agents should not guide the applicant to sign or date it during the pre-AEP, but instead should encourage applicants to sign and date it the day they actually mail it, between october 15 and December 7 (not earlier than October 15, 2013).
- Important note: The Humana enrollment department must receive the application by December 7, 2013 in order for it to be considered a valid AEP enrollment. CMS requires us to go by "receipt date" not postmarked date.
- An agent must leave the entire application with the member along with an envelope addressed to: Humana Medicare Enrollment, 2432 Fortune Drive, Lexington, KY 40509. The agent must also state that the application should be sent to Humana for receipt after October 15. Do not coach applicants to send in the application to Humana for receipt prior to the October 15 date. As a reminder, any application received prior to the start of AEP with an agent name on it will result in an investigation to determine if the agent took possession of or solicited the application prior to AEP. Beginning October 15, 2013 agents can begin accepting enrollment applications and should date them appropriately.
A complete set of the Chapter 3 Marketing Guidelines may be found on CMS' website at the following web address:
2. Using the New "Benefits at a Glance" Tool
The Benefits at a Glance document can be used during the suitability assessment phase at the beginning of the sales appointment to assist beneficiaries in making plan comparisons. Or it can be used after the fully compliant sales presentation has been given to help the beneficiary decide which specific plan would be the best fit. To reiterate: The Benefits at a Glance document does NOT replace the use of the Summary of Benefits in the sales process.Coincidentally, if a beneficiary decides after reviewing the Benefits at a Glance document that a different plan than was originally presented might be a better fit, the agent must ensure that a full sales presentation was given and the Summary of Benefits is reviewed for the selected plan. (The Benefits at a Glance is shipped automatically with the Summary of Benefits.)
Questions and Answers
Q: Can the Benefits at a Glance document be used as a stand-alone piece?
A: Yes, it can be used as a stand-alone piece to show beneficiaries what plans we have available. Agents can also place the document in the plastic sleeve found in the Enrollment Book. However, it does not replace the compliance requirement of covering the full Summary of Benefits and all other required documents that must accompany an enrollment form.
Q: If an agent staffing a Walmart store has someone walk up and ask general questions about our products, could an agent pull out a Benefit at a Glance document and discuss the basics from it?
A: Yes, however, if the beneficiary shows interest in hearing more about a particular plan, a scope of appointment should be secured and a fully compliant sales presentation must be given with the use of the Summary of Benefits.
Q: Since we are allowed to discuss the basics from the Benefits at a Glance document, can agents hand it to a beneficiary to take with them, even if no SOA is secured for a full presentation and Summary of Benefit discussion?
A: Yes, however, an agent cannot enroll someone who has not received a fully compliant sales presentation which includes a comprehensive review of the Summary of Benefits.
3. Using Interpreter Services
There is no way we can speak all the different languages of the beneficiaries we are trying to help. Luckily we don't have to. CMS requires all plans to provide an interpreter service notice (also known as the Multi-Language Insert) with enrollment kits. The notice must be left with the prospect at every appointment. The notice includes the following statement translated into 15 languages (Spanish, Chinese, Tagalog, French, Vietnamese, German, Korean, Russian, Arabic, Italian, Portuguese, French Creole, Polish, Hindi, and Japanese):
"We have free interpreter services to answer any questions you may have about our health or drug plan. To get an interpreter, just call us at [1-xxx-xxx-xxxx]. Someone who speaks [language] can help you. This is a free service."
What Should Agents Do?
The Multi-Language Insert is incorporated into the Summary of Benefits document again this year. Make sure you review this insert with each prospect. Regardless of the sales setting, you will want to call the prospect's attention to the insert in the event someone in the room may need additional assistance. This is extremely important as CMS secret shoppers specifically look to see if agents are reviewing the insert! If you recognize the need for a language interpreter to participate during an appointment, call the number provided for interpreter assistance. The Medicare beneficiary can also call this number after the appointment or anytime in the future for assistance.
Agents are also responsible for providing a sign language interpreter for the hearing impaired upon request from any beneficiary, prospect or member ("customer") for any type of meeting. This is required by the American's with Disabilities Act ("ADA") and Humana's policies and procedures. The locations at which agents may provide sign language interpreters include, but are not limited to:
- In-home presentations
- Informational tables or kiosks at retail locations (such as Walmart), or other locations (like shopping malls or health fairs)
- Other locations as determined by circumstances and/or request by customers
Agents should work with their local Humana sales management to arrange for a sign language interpreter. The cost of providing the sign language interpreter is at Humana's expense. IMPORTANT! - If an agent is not aware of the need for a sign language interpreter prior to the appointment or meeting but learns that a hearing impaired customer desires to have one present, the agent should reschedule the appointment for a time when he/she can arrange for a sign language interpreter to be available.
In addition, agents may access Humana's TTY number for assistance in communicating with hearing impaired customers. TTY Users - Call Humana's TTY number for assistance: Toll Free: 1-800-372-2147; TTY Users: 711.