On April 26, 2019, the Centers for Medicare & Medicaid Services (CMS) released Communications Accessibility for Individuals with Disabilities – Best Practices for Medicare Health and Part D Prescription Drug Programs. This document was submitted to the agency by IMPAQ International, LLC. The report focuses on auxiliary aids and services addressing communication-related accessibility needs, as those cover typical beneficiary interactions.
About a year and a half ago, some colleagues and I authored a white paper titled Accessible Communications: Standing Tall in Service. We realized the importance of this topic as the agency had released frequently-asked questions related to Section 504 of the Rehabilitation Act of 1973 (Section 504) and Section 1557 of the Affordable Care Act (Section 1557). I’m happy to report many of our recommendations and best practice concepts are also found in the IMPAQ piece, such as cultural competency training, leveraging qualified readers, tracking/maintaining beneficiary requests, analysis of complaint data, and auditing/monitoring of vendors. IMPAQ covers more in the arena of web accessibility, whereas I respectfully believe we covered more from a delegation oversight standpoint.
The reason we wrote this piece was because our number one priority was beneficiary access to care and service. I know for a fact the piece was not as popular as anything related to CMS program audits or marketing materials. Now that CMS has released these best practices, plans and delegates should sit up and take more notice of this topic. This could be a harbinger of things to come.
A site any compliance or operations professional should be monitoring regularly is the Paperwork Reduction Act (PRA) listing. This page is a gold mine if you are looking to shape what you need to implement later. If I could change PRA to stand for something else to illustrate the importance, it would be Please Read, then Act!
Typically, this is where the Centers for Medicare & Medicaid Services (CMS) posts proposed changes and requests for information or comment. For example, when the agency proposes to change Part D reporting technical specifications, the changes and supporting statements are posted on this site. This gives the public (you!) the opportunity to review and provide comment within a comment period. And it is not just Part D; you will find documents related to other programs such as Fee For Service Medicare, PACE, Exchange and Medicaid.
Let’s walk through an example. CMS posted their proposed changes and supporting statement for the Notice of Denial of Medical Coverage (or Payment) (NDMCP – those pesky denials). Upon review of the proposed changes, I identified two areas of opportunity. In one instance, there is room to further clarify language directed at a beneficiary filing an appeal, and in the other instance, there is opportunity to clarify the instructions to the plan. To submit comments electronically, I went to regulations.gov and found the document in question, hit the “Comment Now!” button and voilà – submitted.
Implementation is not simple. Do not get caught in a situation where you struggle with something confusing, arguably unreasonable, or impossible to complete. Take the opportunity to review this site often, or subscribe to the RSS feed to be notified more quickly. You may often find something the agency missed, or you may provide an improved solution that reduces burden on you, your organization, and your beneficiaries.