Updates - Medicare Open Enrollment Period, Starting October 15

The Annual Election Period (AEP) – the period during which individuals with Medicare can make coverage elections regarding Medicare Advantage (MA) and Part D plans for the following year – will start October 15th and last until December 7th. This period is sometimes referred to as the Open Enrollment Period (OEP).

Below is some information issued by the Centers for Medicare & Medicaid Services (CMS) about 2021 Medicare Advantage and Part D plan offerings, and by the Administration for Community Living (ACL) about CMS mailings and notices. 

Also below, the Center for Medicare Advocacy expresses our ongoing concern about CMS’ continued steering of beneficiaries towards MA enrollment.

2021 Plan Information

Information about 2021 MA and Part D plan offerings is available on the Medicare Plan Finder at medicare.gov starting today, October 1st.

On September 24, the Centers for Medicare & Medicaid Services (CMS) issued a press release about 2021 plan offerings. The following links to additional information about such offerings are reproduced from the press release:

• To view the premiums and costs of 2021 Medicare Advantage and Part D plans, please visit: https://www.cms.gov/Medicare/Prescription-Drug-Coverage/PrescriptionDrugCovGenIn/index.html. Select the various 2021 landscape source files in the downloads section of the webpage.
• To view a chart on the Medicare Advantage premium change between 2017 and 2020 on a state-by-state basis, please visit: https://www.cms.gov/files/document/medicare-advantage-premium-change-between-2017-2020.pdf.   
• For state-by-state information on Medicare Advantage and Part D in 2021, please visit: https://www.cms.gov/files/document/2021-ma-part-d-landscape-state-state-fact-sheets.pdf.
• For more information on the Part D Senior Savings Model, including plan participation, please visit: https://innovation.cms.gov/innovation-models/part-d-savings-model.
• For more information on the Medicare Advantage Value-Based Insurance Design Model, including plan participation, please visit: https://innovation.cms.gov/innovation-models/vbid. A fact sheet on the CY 2021 participation in the Medicare Advantage Value-Based Insurance Design Model is attached and available at: https://www.cms.gov/newsroom/fact-sheets/medicare-advantage-value-based-insurance-design-model-calendar-year-2021-model-participation

CMS Mailings Chart and Key Notices

The Administration for Community Living (ACL), which oversees State Health Insurance Assistance Programs (SHIP) programs, issued the following information to SHIPs and other Medicare stakeholders.  We reproduce it here:

The following CMS mailings chart and HPMS plan memos regarding required notices serve as reminders of the notices beneficiaries will receive in coming weeks:

1. CMS mailings chart includes hyperlinks to model notices (standard language) from CMS on colored paper as well as plan notices. Keep this chart handy as beneficiaries will often refer to the color of the notice received https://www.cms.gov/Medicare/Prescription-Drug-Coverage/LimitedIncomeandResources/Downloads/Consumer-Mailings.pdf  See the NCOA provided detailed explanation of the notice chart https://www.ncoa.org/wp-content/uploads/AEP-guide-to-mailings-and-key-events.pdf
   Key highlights of CMS notices in coming weeks
• By Sept 30
1. Annual Notice of Change (ANOC) from plan
2. Extra Help/LIS deemed status loss letter from CMS
3. Medicare and You Handbook from CMS
• Plan marketing materials starting Oct. 1 from plans
• Plan non-renewal and LIS notices by Oct. 2- 3 from plan

2. HPMS plan memos on Extra Help Reassignment
• Prescription Drug Plan (PDP) zero premium reassignment
1. Beneficiaries who have chosen their own plan (themselves or with help from another, like a SHIP counselor) or who no longer qualify for Extra Help in 2021 will not be reassigned. These beneficiaries will receive a notice from CMS listing zero premium plan choices in their service area in late Cot. (see mailings chart). The plan list is a starting point. Beneficiaries may need SHIP counselor comparison help to determine whether the plans on the list cover their specific medications (must on formulary be to get LIS price) and whether utilization management rules (like quantity limits, step therapy) apply.
• Medicare Advantage service area changes reassignment
1. Applies to beneficiaries with Extra Help in 2020 and 2021
2. By Oct. 3, beneficiaries must receive notice of reassignment

Ongoing Steering Towards Medicare Advantage Plans

Since Fall 2017, the Center for Medicare Advocacy has expressed concerns about bias towards Medicare Advantage in CMS materials, including outreach and enrollment materials, email campaigns and the 2018, 2019 and 2020 Medicare & You handbooks (see, e.g., here, here and here).

On September 18, 2020, the Center released an Issue Brief titled “Medicare & You 2021 – An Assessment of Bias in Favor of Medicare Advantage” which provides an in-depth analysis of the new handbook and the ways in which it treats Medicare coverage options in a way that is not balanced or neutral, as it should be.

As noted in our analysis the 2021 Medicare & You handbook, throughout CMS education and outreach materials, in recent years there has been a focus on “plans”, often implying that a Medicare “plan” is the only or best option for individuals. CMS’ repeated reference to plans undermines the option of Original Medicare, and assumes that private MA plans are the default option. While people with Original Medicare may have stand-alone Part D plans, which they would be advised to review every year, CMS language has often blurred the distinction between MA and Part D plans and refers to them as “health and drug” plans or other characterizations that imply that they are either one and the same, or that a combination of both (a Medicare-Advantage Prescription Drug, or MA-PD) is the best choice.

It appears that the 2020 CMS email campaign will continue in this vein.  On September 25, the Center received the first CMS Fall 2020 enrollment period email entitled “Plan ahead for Medicare Open Enrollment.” The email states, in part (emphasis in original):

Medicare Open Enrollment begins October 15! This year, Medicare plans have historically low premiums — dropping an average of 34% over the last 3 years, and in some states up to 60%! Starting October 1, you'll be able to take a sneak peek at plans available in your area.

If you're among the 1 in 3 people with Medicare who has diabetes, here's some more good news: many participating drug plans will offer a 30-day supply of insulin for $35 or less starting January 2021.

Think you'll need help comparing plans once Open Enrollment begins? Here are some things you can do from the safety of your home:

• Find Plans at Medicare.gov,where you can see estimates for all your prescriptions.
• Look at the eHandbook (also available in accessible formats like Braille, large print, and data/audio files).
• Call us at 1-800-MEDICARE during Open Enrollment.”

Similarly, on October 1 CMS sent another email with the heading “Sneak peek into Open Enrollment” which states, in part (emphasis in original):

Medicare Open Enrollment starts October 15 — but you can get a head start by previewing 2021 plans today! Now's a great time to review your coverage and see if there's a better fit for you. Plans have historically low premiums — dropping an average of 34% over the last 3 years, and in some states up to 60%!

Here's something new for Open Enrollment: Many participating drug plans will offer a 30-day supply of insulin for $35 or less in 2021. Visit Medicare.gov now to preview participating plans ahead of Open Enrollment.

Remember: When comparing plans, look at the estimated "Yearly Drug & Premium Cost." A plan with the lowest premium may not always provide the lowest total cost to you.

While this email adds the important caveat that the lowest premium does not necessarily mean the lowest total cost, the promotion of  generic “plans” blurs distinctions between plan types, and is not geared towards someone who wishes to remain (or switch to) traditional Medicare

The complaints the Center has received about the September 25^th email include one from an insurance agent whose client with a Medicare supplemental policy (Medigap) received this email. As noted by the agent, “You know how inappropriate this is as it is only partly true, and is in essence advertising for Medicare Advantage plans.” We couldn’t agree more.