Thinking of playing in the 2019 Medicare Advantage sandbox?

By Julie Mason

Ah, autumn.  The rustle of falling leaves, glowing Jack-o-’lanterns on front porches, and pondering whether to join the Medicare Advantage fray.

One can ponder the possibility for a few more months until the hard deadline of January 26 to submit a Notice of Intent to Apply (NOIA) to CMS.

But the early bird is guaranteed access to the online application on CMS’ all-important Health Plan Management System (HPMS) if the NOIA is submitted to CMS by November 13.

Filing the NOIA is easy; a simple and straightforward online form can be found and submitted at https://cmsgov.wufoo.com/forms/m1a57pn903l439i/ (for new entrants in the Medicare Advantage (MA) or Prescription Drug Plan (PDP) space or those looking to add a different type of MA contract to their product portfolio) or https://cmsgov.wufoo.com/forms/m1yb3pho0rgfunf/ (for current MA plans or PDPs looking to expand their service area or add a Special Needs Plan).   (Medicare-Medicaid Plans (MMPs) can find the applications for new and SAE applications at these links: https://cmsgov.wufoo.com/forms/mh7wrvo0oxg7d3/ and  https://cmsgov.wufoo.com/forms/mdd9qlk0in363z/).  And filing a NOIA does not commit you to applying for an MA/PDP/MMP contract or service area expansion, so no worries if your Chief Actuary crunches the numbers and gives you a thumbs down, even as late as the 2016 application filing deadline, February 14.

That said, the sooner a decision is made to proceed with the application, the better.  Completing the CMS application to be a newbie Medicare Advantage plan is not for the faint of heart.  Unlike the NOIA—remember, simple and straightforward—the MA application itself is anything but.  And if you plan to offer Part D coverage with that MA plan, it involves an additional and separate application.  Iff you’re considering offering a Special Needs Plan (SNP) on top of that…well, just give your staff plenty of notice not to schedule any mid-winter ski vacations.  February 14 will come way too soon next year and there will be many long nights between now and then.

Having previously been a CMS regulator for, well, more years than I care to say, and having reviewed many a new Medicare health plan application in those days as well as assisting plans complete applications in more recent years, I can say with certainty that the devil is in the details.  And there are many, many details to be attended to.  And the CMS application reviewers are VERY good at finding the missed details.  CMS takes the application process very seriously, and applicants are advised to do the same.

The 2017 MA and Prescription Drug Plan (PDP) applications will be posted on the CMS website on January 9, 2016, but many applicants will begin preparing application documents this fall and early winter using the 2018 application released in January 2017.  This allows for a much-needed head start on the daunting process, and if any of the requirements or application documents change for 2018, one can make the necessary updates or changes to the 2017 versions prepared this fall.

Finally, those considering applying for an MA contract should request membership to the CMS industry listserv for HPMS memos.  Keeping up with CMS policy and guidance issued via HPMS is critical for current MA plans and PDPs, but is also extremely useful for new applicants.  In addition to receiving critical information related to the application process (such as announcements of CMS training on the 2017 application process—a ‘must see’ event), it provides a taste of the complexity and intensity of the MA and Part D programs.  To request access to the industry listserv, click here or go to https://www.cms.gov/Medicare/Medicare-Advantage/MedicareAdvantageApps/index.html?redirect+/MedicareAdvantageApps.  If you have not yet subscribed to the industry listserv and would like a copy of the NOIA memo from CMS, message MCS through our contact page for a copy.

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