Today, the Centers for Medicare & Medicaid Services (CMS) posted a memo regarding the Medicare Communications and Marketing Guidelines (MCMG), and yesterday, CMS published two memos: HPMS Marketing Module Updates and Model Notice Corrections and Updates. I’ll address today’s memo first.
In an interesting turn, CMS is instructing plans to refer to the 2019 MCMG guidance in conjunction with the updated guidance provided in today’s memo. Changes are designed to clarify scope and minimize burden. There are a number of clarifications that will affect your 2020 material review initiatives. It is also important to note CMS releases this noting it is “pending issuance of updated guidance,” which could be indicative of a delayed 2020 MCMG document.
Regarding the marketing module updates, the agency provides a comprehensive list of retired codes and provides new codes for benefit highlights and CMS-requested communications. CMS also provides additional operational clarifications and updates which should be incorporated into plan processes.
As it happens every year, the agency has published a list of corrections and updates to their model notices released in May. Some changes are run-of-the-mill clarifications to language. However, there are quite a few changes to support changes to the handling of Part B drug requests. In 2020, plans may start applying step therapy to Part B drugs, so additional instructions have been added to plans to disclosed a complete list of Part B drugs subject to these requirements. Furthermore, CMS modified Part C adjudication timeframes for organization determinations and appeals for Part B drugs as part of their Final Rule, so additional language was added to clarify the Part B prescription drug coverage decision and appeals decision timeframes. Since new models have not been posted, it is imperative for plans to ensure all materials take these changes into account.