Non-Renewing Plans and Service Area Reductions
CMS recently published guidance about the handling of Medicare Advantage plans that are not going be renewed for the coming year (non-renewals) and service area reductions where the members who reside in that part of the service area will lose coverage. For members impacted by either of these actions, they will be have to choose some other form of coverage for the 2014 plan year. In its guidance, CMS has specifically addressed marketing to those impacted by a non-renewal or service area reduction.
The CMS guidance specifically states the following:
"Please note that no information about the non-renewal or service area reduction may be released to enrollees, providers, or to the public prior to September 18, 2013. Any marketing to members of a non-renewing plan, whether the plan's own members or a competitor's, may not take place until October 2, 2013."
This CMS guidance means that agents may not call, mail or contact clients who will be impacted by a non-renewal or service area reduction to discuss other plan options ANY EARLIER than October 2nd. That is the date that all impacted members across the country are required to have received a notice from their plan informing them that the plan they have is not going to be available for 2014.
If the member has already received notice that their plan is one that is not renewing and asks the agent about the letter they received, the following is an appropriate agent response to be given to the member inquiry:
"The letter you received means that the plan you have now won't be available next year so you will have to select some other coverage. Information about our 2014 plan options are available in Oct. If you'd like, we can set up an appointment to meet starting to review other plan options you might want to consider since your plan is not going to be available. If you'd like to meet, I can mail a form to you that I need you to complete and mail back to me before our meeting that will outline what plan types you want to learn more about when we do get together."
As a reminder, those impacted by a non-renewal or service area reduction qualify for the SEP for non-renewing plans (SEP-NON). That SEP begins Dec, 8 and runs through the end of February. If the member selects a plan via the AEP, and it becomes effective January 1st, they still have an SEP election they can use if they wish to change their mind.
Attached is the list of Humana's non-renewing plans by contract/PBP and county. The last column identifies if there is an alternative plan in the service area. If there's no MA plan available, then Medicare Supplement and PDP information will be populated.
If you have questions, please contact your Humana account executive.