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6 th Annual SNP Leadership Forum Danielle Moon, J.D., M.P.A. Director, Medicare Drug & Health Plan Contract Administration Group The Centers for Medicare & Medicaid Services October 29, 2010
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Update on Affordable Care Act Rulemaking CMS has developed a proposed rule that we anticipate to be released in the near future The comment period for the proposed rule will be sixty days 2
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Trends in SNP Landscape In 2010 - 562 total SNPs vs. in 2011 - 451 total SNPs Despite the decline in SNP plans, total enrollment has dipped only slightly Perspectives on decline in SNP plan offerings: Consolidations - MAOs may have consolidated those SNPs with few enrollees when feasible. MIPPA law slowed growth with new requirements: Required any new or expanding dual SNP to enter into a contract with the State. Chronic Care SNPs - limited to fifteen (15) conditions that met the MIPPA-clarified definition of "severe or disabling” causing some non- renewals and consolidations. MIPPA law ended authority for “disproportionate share” SNPs. 3
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Submission of SNP Proposals for Contract Year 2012 The Affordable Care Act mandates that for 2012 and beyond, ALL SNPs must be approved by NCQA, based on standards established by the Secretary. 4
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Marketing Rules 5
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Clarification of Provider Based Activities 6
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Section 70 - Promotional Activities, Events and Outreach Providers may assist a beneficiary in an objective assessment of the beneficiary’s needs and potential plan sponsor options Providers may engage in discussions with beneficiaries when patients seek information or advice Discussions with providers regarding Medicare options should be initiated by the beneficiary 7
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Section 70 - Promotional Activities, Events and Outreach Provider-based activities and provider affiliation announcements Appointments to discuss MA or Part D plans may be made in long-term care (LTC) facilities when requested by the beneficiary Providers can display information from all plans with which they contract CMS does not expect providers to proactively contact each sponsor to collect the marketing materials 8
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Section 70 - Promotional Activities, Events and Outreach cont’d Providers may conduct the following in LTC facilities: Display posters Include materials in admission packets Provide residents that meet I-SNP criteria a brochure for each I-SNP with which the facility contracts 9
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Section 70 - Promotional Activities, Events and Outreach cont’d Long-term care facility staff are permitted to provide residents that meet I-SNP criteria an explanatory brochure that includes: Qualification criteria and benefits A reply card or telephone number for the resident or responsible party 10
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Section 70 - Promotional Activities, Events and Outreach cont’d Providers may feature SNPs in a mailing announcing an ongoing affiliation Mailing may highlight provider’s affiliation or arrangement and may include specific information about the SNP Announcement must list all other SNPs with which the provider is affiliated 11
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Clarification of Other Marketing Issues 12
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Other Marketing Requirements Responsible Parties: CMS’s marketing guidelines are limited in scope to communications with Medicare beneficiaries Section 40.2.1 of Chapter 2 of the Medicare Managed Care Manual provides guidance regarding legal authorized representatives State law governs who may make enrollment and health care decisions for beneficiaries 13
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Other Marketing Requirements Unsolicited Contact: Plan sponsors are permitted to contact beneficiaries who have expressly given permission Permission applies only to the entity which the beneficiary requested contact Plan sponsors may send mailings that provide information regarding ISNPs 14
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Model Marketing Materials 15
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2012 Model Marketing Materials Development of one or more SNP ANOC/EOC model templates for CY 2012, including focus groups and advocate and industry listening sessions Revisions to SB sentences on MOOP and Part D premiums Consumer testing of additional model materials with beneficiaries Efforts to “plain language” additional model marketing materials Identification of additional model materials for standardization 16
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Dual SNP Contracting Issues 17
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Dual SNP Contracting Issues CMS is currently reviewing the contract submission timeframe. Considerations include: *State contracting timeframes *The due date of the bids *Due dates for marketing materials 18
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Dual SNP Contracting Issues (cont.) Technical Assistance Provided CMS developed a State Resource Center Website which has helpful information to States and SNPs CMS maintains a mailbox whereby States may submit questions and request assistance Central Office and the Regional Offices communicate regularly to discuss issues impacting SNPs CMS has held three Sharing Teleconferences with the States 19
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Dual SNP MIPPA Contracting issues (cont) Crosswalk flexibility for Dual SNPs Seeking State contracts An exception may be considered for new Dual SNPs with State contracts, where the old dual SNP (w/o State contracts) may have covered multi-State areas 20
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Resources Mail box: State_Resource_Center@cms.hhs.gov State_Resource_Center@cms.hhs.gov Web Address: http://www.cms.hhs.gov/SpecialNeedsP lans/05_StateResourceCenter.asp#Top OfPage http://www.cms.hhs.gov/SpecialNeedsP lans/05_StateResourceCenter.asp#Top OfPage 21
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SNP Team Contacts LaVern Baty 410-786-5480 Lavern.Baty@cms.hhs.govLavern.Baty@cms.hhs.gov Camille Brown 410-786-0274 Camille.Brown@cms.hhs.gov Caroline Farrell 410-786-0228 Caroline.Farrell@cms.hhs.gov Mervyn John 410-786-1141 Mervyn.John@cms.hhs.gov Gia Lawrence 410-786-2749 Gia.Lawrence@cms.hhs.gov Eric Nevins 410-786-1162 Eric.Nevins@cms.hhs.gov Melissa Staud 410-786-3669 Melissa.Staud@cms.hhs.gov 22 MAY CONTAIN INFORMATION THAT IS NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW: This information has not been publicly disclosed and may be privileged and confidential. It is for internal government use only and must not be disseminated, distributed, or copied to persons not authorized to receive the information. Unauthorized disclosure may result in prosecution to the full extent of the law.
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