CMS Proposes Changes to Special Election (LIS), Return of OEP

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2017-11-16 - Centers for Medicare & Medicaid Services

Changes being considered for 2019

Limitation to the Part D Special Enrollment Period for Dual and Other LIS-Eligible Beneficiaries
To ensure that Part D plan sponsors are better able to administer benefits, including coordination of Medicare and Medicaid benefits, we are proposing to change the Special Election Period (SEP) for dual-eligible and LIS beneficiaries from an open-ended monthly SEP to one that may be used only in the following circumstances (and only if the beneficiary has not been identified as potentially at-risk or at-risk): (1) within a certain period of time after a CMS or State-initiated enrollment; or (2) as a onetime annual opportunity that can be used at any time of the year. The proposed rule would establish a separate SEP that can be used by any dual or other LIS-eligible beneficiary, including those who have been identified as potentially at-risk or at-risk, within a certain period of time after a change to an individual’s LIS or Medicaid status.

This one sounds like a done deal:

Restoration of the Medicare Advantage Open Enrollment Period
The 21st Century Cures Act eliminates the existing MA disenrollment period (MADP) that currently takes place from January 1st through February 14th of every year and, effective for 2019, replaces it with a new Medicare Advantage open enrollment period (OEP) that will take place from January 1st through March 31st annually. The new OEP allows individuals enrolled in an MA plan to make a one-time election to go to another MA plan or Original Medicare. Individuals using the OEP to make a change may make a coordinating change to add or drop Part D coverage. Codification of Part A and Part B Premium Adjustments as Initial Determinations CMS is proposing to codify the existing policy of treating fee-for-service premium adjustments as initial determinations, which gives them full appeal rights.
 
So no AEP? Or is this something in addition? The oep that is.

Sounds like it may be going back to how it once was. There will still be an AEP. But then from January 1 to March 31, people will be able to make a one time change during OEP. This will be the time where all the people you helped during AEP will be contacted and made to think they made the wrong decision. Which will result in more work just trying to re-educate your clients as to why you enrolled them in the plan you did and why they should stick with it and not change.
 
From the way that I read it. I definitely got that AEP is still going to be there, CMS is extending the time period and calling it OEP for a one-time get out of "jail" free card. Might be a good time for some follow up appointment work to keep money on the books and check in.
 
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