The Department of Health Care Services (DHCS) is announcing two enrollment updates to the Cal MediConnect program.
When Cal MediConnect and the CCI were launched, DHCS, in collaboration with stakeholders and participating health plans, set a policy to not allow independent brokers to receive compensation for Cal MediConnect plans the same way other Medicare Advantage plans and D-SNPs allow for such compensation. This has placed Cal MediConnect at somewhat of a disadvantage compared to other types of Medicare plans, as independent brokers have no incentive, and sometimes a disincentive, to educate beneficiaries about Cal MediConnect. In fact, with the current restrictions in place, independent brokers have been selling non-integrated Medicare plans to beneficiaries at increasing rates, resulting in more beneficiaries in unaligned Medicare and Medi-Cal plans for their care.
Following the end of passive enrollment, we have made several improvements to our enrollment rules to help beneficiaries more easily make choices. For example, the streamlined enrollment process allows Cal MediConnect plans to submit enrollment requests to our independent enrollment broker, Health Care Options (HCO), on behalf of their Medi-Cal members. Streamlined enrollment was created with several beneficiary protections, including outbound calls from HCO to the beneficiary to confirm their choice.
Under a new pilot program for plan year 2019, participating Cal MediConnect plans will be able to pay independent brokers when a beneficiary chooses to enroll into Cal MediConnect. Plans will have to seek approval from DHCS to participate in this pilot, DHCS expects to prioritize proposals from plans not operating any other Medicare Advantage plan in the county. These broker payments will be made with plan funds – no additional dollars will be available for this purpose.
For plans approved to use the new broker enrollment pilot process, enrollment will be facilitated like streamlined enrollment. With the exception that independent brokers will be able to work with any eligible beneficiary, not just members in a Medi-Cal product operated by the same Cal MediConnect plan. Enrollment requests from independent brokers will go from the plan through HCO (except for county operated health system (COHS) plans, which continue to facilitate enrollment) to ensure that only beneficiaries who are eligible for Cal MediConnect are enrolled. In addition, HCO will conduct the same outbound phone calls to beneficiaries to ensure the plan enrollment is their choice.
The Cal MediConnect continuity of care provisions that allow beneficiaries to see their existing Medicare and Medi-Cal providers will apply for beneficiaries enrolled through this process. We’re working with CMS to provide additional guidance to selected plans on tracking and reporting independent broker enrollments, performing required training for independent brokers, and for oversight of the pilot.
Plans wishing to participate in this pilot must request approval by June 30th.
DHCS will be seeking a waiver to new Medicare enrollment regulations that would limit Special Election Periods (SEP) for Cal MediConnect.
Historically, a key beneficiary protection in Cal MediConnect has been the beneficiary’s ability to make enrollment changes monthly. This was based on enrollment policies in both Medi-Cal and Medicare allowing this population (dual eligibles) the ability to change plans or return to fee-for-service Medicare without limits on a monthly basis. This is known as a “continuous” SEP in Medicare.
Medicare recently finalized a regulation for 2019 with several changes, which included new limits on the continuous SEP for dual eligible beneficiaries. Under the new regulations, dual eligible beneficiaries would be limited to changing Medicare plans just once a quarter for the first three quarters of each calendar year. This is in addition to the open enrollment period between October and December that is open for all Medicare beneficiaries. Additional SEPs continue to be available, such as moving out of a service area or to enroll in PACE (Program of All-Inclusive Care for the Elderly).
DHCS requested input from stakeholders on whether Cal MediConnect should be updated to be consistent with the new Medicare rules or if DHCS should seek a waiver to maintain the continuous SEP. Based on this feedback and internal discussions, DHCS will seek a waiver to maintain the continuous SEP in calendar year 2018. This will apply to dual eligible beneficiaries enrolling into, switching among, or disenrolling from Cal MediConnect plans.