Effectively Handle Large Scale AEP 2023 CMS Changes in ANOC and EOC Model Documents

The Center for Medicare & Medicaid Services (CMS), the federal body that regulates and administers the Medicare and Medicaid programs, releases changes to the Annual Notice of Change (ANOC) and Evidence of Coverage (EOC) model documents every year in late spring. Complex and elaborate, these model documents provide the content and layout guidelines for Medicare Advantage Organizations (MAOs) to create the required compliance and marketing communications for all their Marketed Plans. MAO’s are required to have these communications ready for members before the start of the Annual Enrollment Period (AEP), which runs from October 15 to December 7 every year.

The ANOC and EOC provide vital information for potential and current plan beneficiaries, who can add to, change, or drop their Medicare Advantage or Medicare Part D plan coverage during the AEP. The CMS requires all MAOs and Part D sponsors to ensure all beneficiaries receive the newly updated, compliant, and accurate ANOCs and EOCs for their marketed plans well ahead of the AEP, so they have enough time to make informed decisions about their coverage for the upcoming year.

In recent years, the CMS has maintained the general structure of the model ANOC and EOC documents, making only relatively minor changes. Having fewer and smaller updates to follow made it easier for MAOs to prepare their own documents in a timely fashion. However, in May 2022, the CMS published the AEP 2023 model documents, and the changes are anything but minor. Many MAOs were caught off guard, and are now facing the most significant update process they’ve had in years.

A Much-Needed Update

These major changes are in themselves, a positive step toward making complex documents more recipient friendly. The Obama administration mandated that government communications need to be clear, concise, and readable. ANOCs and EOCs are contractual legal agreements, written at a grade 12 level: only a small minority of Americans read at level nine or higher. Simplifying the language level makes these important documents more approachable to more people. Another factor in readability is length: complex EOCs can be up to 300 pages long, a daunting size for many.

The key changes in the CMS 2023 model documents include:

• Increased use of plain language, to make them simpler for beneficiaries to understand
• Elimination of duplicate language and specific tables, to help beneficiaries avoid confusion
• Removal of some interior Tables of Content, so beneficiaries can navigate the document more easily through a single, more detailed Table of Contents
• General reorganization focused on simplifying and shortening the document
• Reduction in the overall size and length by 15-20%

For the 43% of Americans who have low literacy skills, these long-awaited adjustments are very welcome changes. Trimmed, simplified, and more consistent, the new concise ANOCs and EOCs will help beneficiaries make their Medicare & Medicaid choices with clarity and confidence in the upcoming AEP. But for MAOs with dozens of plans under management, these dramatic cuts and changes can pose serious logistical problems when it comes to building, proofing, translating, and printing the documents.

Recognizing the magnitude of the transformation, the CMS released its model documents a few weeks early this year, in an attempt to give MAOs some extra time to incorporate the new modifications. However, the due date for these documents is still the same, which means MAOs have to analyze and integrate the changes in a short period, in accordance with their CMS plan filings. Depending on their internal documentation process, some MAOs will find the update a laborious task.

Contingent on their choice of tool, their process requirements, current staffing levels, and vendor relationships, some MAOs may not be adequately prepared to make all the necessary changes in time to meet CMS requirements. That’s true even if MAOs outsource the entire process: third-party service providers face all the same challenges and can put MAOs at risk of missing key deadlines.

At Messagepoint, we proactively helped our clients face this formidable task. First, we reached out to CMS to understand the scope of changes, planned for this work, and then contacted our clients, both to ensure they were aware of and understood the extent of the changes and to share our detailed implementation plan.

In the last month & a half, Messagepoint has worked diligently to seamlessly migrate our clients to the new model documents. The CMS data & model content updates are part of the Messagepoint subscription and Messagepoint clients don’t have to do this work themselves. When core model documents are built, the Healthcare Touchpoint Exchange allows common format and content to be subscribed to and synched to local documents. Our clients can smoothly adapt the CMS’s latest changes to their own materials.

Big Changes are Coming: Be Ready

The sheer size and scope of the latest CMS changes make it clear that many MAOs need to rethink how they create their CMS-mandated communications. A manual approach or a generic document automation platform is no longer enough; nor is it feasible to rely on third-party print providers. It’s time to look for a specialized, pre-configured solution that comes with all the features and perquisites MAOs need most. Automation is required, and the choice of technological tools will be critical.

Messagepoint Healthcare Touchpoint Exchange is a purpose-built platform integrated with CMS PBP data. The latest CMS model content and layout – with all the major changes — are already configured, and annual CMS model updates are supported as part of every subscription. In addition, the platform offers a fully integrated QA model which supports review and remediation and provides a trackable audit trail. Translation and accessibility are built right in: Spanish content is already configured, and Plan document versions can be created in both regular and large print.

The CMS has made major changes this year and there could be more changes expected in data and content in the coming years. It’s time to make your own changes – ease the load on your team, reduce your risk, and take back control of your AEP updates with smart automation.

Find out how Messagepoint can help you seamlessly accommodate large-scale updates to CMS model documents. Contact us for a demo.