Plan Selection, Readiness, & Data Reporting Overview
Today, DHCS is announcing that L.A. Care is the only Cal MediConnect plan which applied and qualifies for the Cal MediConnect Agent/Broker Pilot. The following is a summary of the plan selection process, the readiness review the plan must meet, and the data/reporting requirements to provide oversight of the pilot and ensure consumer protections.
Plan Selection Process
In reviewing Cal MediConnect plan requests to participate in the Agent/Broker Pilot, DHCS verified that:
- Cal MediConnect is the only Medicare product offered by the plan.
- The plan has policies and procedures to collect enrollment requests from agents/brokers, ensuring that brokers understand and route the enrollment requests through the Cal MediConnect plan and not through Medicare.
- The plan has updated their streamlined enrollment policies and procedures to include agent/broker enrollment submission processes. (For COHS plans, their Cal MediConnect enrollment policies and procedures have been updated to include agent/brokers.)
- The plan attested to abide by all requirements set forth by CMS’ Medicare Managed Care Manual (MMCM), CMS’ Prescription Drug Benefit Manual (PDBM), Medicare Communications and Marketing Guidelines (MCMG), and regulations at Title 42 of the Code of Federal Regulations, Parts 417, 422, and 423).
- The plan submitted agent/broker business agreements that comply with HIPAA requirements. In addition, the plan submitted policies and procedures that demonstrate and confirm that beneficiary data will not be disbursed or shared beyond agent/broker.
Readiness Review: Agent/Broker Training and Consumer Protections
In addition to reviewing the submitted policies and procedures outlined above, as well as CMS’ standard 2019 agent/broker requirements, DHCS and CMS are requiring participating plans to conduct trainings or readiness reviews to ensure agents and brokers can:
- Comply with existing Medicare/CA-demonstration specific marketing rules
- Comply with CMS’ Calendar Year (CY) 2019 Agent and Broker Training and Testing Guidelines
- Can determine if someone is a full-benefit dual eligible and, specifically, Cal MediConnect eligible
- Can explain the benefits of Cal MediConnect, as well as how to navigate a health plan network (including the delegated model)
- Can educate members about the value of enrolling in an integrated product such as CMC, PACE, or FIDE-SNP
- Participate in training on how to work with limited English proficiency beneficiaries, and the important of using beneficiary-facing materials that are culturally appropriate and in Medi-Cal threshold languages
DHCS will work with participating plans to help identify resources to conduct these trainings and comply with these requirements that will help protect consumers.
Data and Reporting
Cal MediConnect plans currently using the streamlined enrollment process must report data to their Contract Management Team (CMT) on a monthly basis. Under the pilot, DHCS will further require plans to report on a monthly basis to the CMT:
- Number of beneficiaries submitted to HCO and the number ultimately enrolled through facilitation by independent agents/brokers
- The beneficiary’s legacy Medicare/Medi-Cal coverage (Medicare FFS/Medi-Cal managed care, a Medicare Advantage/Cal MediConnect/Medicare Part D product, etc.)
- Agent/broker terminations
This data will help the CMT track agent/broker activity, monitor to ensure beneficiaries are not being disproportionately disenrolled from any particular health plan product, and ensure consumer protections.
Every six months, plans participating in the broker pilot will develop a report on the following characteristics of beneficiaries enrolled in the plan through the pilot:
- Language/demographic information
- Legacy Medicare/Medi-Cal coverage
- If the member is still in the CMC plan
If enough data are available to protect beneficiary privacy, a de-identified summary report of this data could be released to stakeholders.