Integrated Marketing Rules and Practices forMedicare and Medicaid Managed CareICRC Study Hall CallOctober 23, 20144:00-5:00 PM EasternThe Integrated Care Resource Center, an initiative of the Centers for Medicare & Medicaid Services Medicare-Medicaid Coordination Office, provides technical assistance for states coordinated byMathematica Policy Research and the Center for Health Care Strategies.

Agenda Welcome, Introductions, and Roll Call Moving Toward Integrated Marketing Rules andPractices for Medicare and Medicaid Managed Care A Review of Coordinated Marketing Strategies andExperiences in the Massachusetts MedicareMedicaid Program Questions and Discussion2

Participants Michelle Herman Soper, Integrated Care ResourceCenter Derek Tymon, One Care Program Contract Manager,Mass Health3

What Does “Marketing” Mean in EachProgram? Medicare and Medicaid define marketing differentlyMedicareMedicaid Health plan communication with Health plan communication withboth potential and current enrolleespotential enrollees that can bethat promotes the plan; informsreasonably interpreted as intendedbeneficiaries that they may enroll or to influence their enrollmentremain enrolled in the plan; explains decisionsthe benefits of enrollment; or Federal Medicaid Managed Careexplains how Medicare services areRegulations for Marketing Activitiescovered under the plan (42 CFR(42 CFR §438.104); other federal§417.428, §422.2260, andMedicaid regulations govern§423.2260)information for current enrollees (42 Requirements are outlined andCFR §438.10)updated annually in the Medicare Each state has additionalMarketing Guidelines (MMG)requirements for Medicaid managed4care marketing

Differences in Medicare & MedicaidRequirements. . . For example: Literacy/reading level standards; Translation requirements; Allowable marketing techniques, includingunsolicited marketing of a plan’s products; Use of independent agents and brokers; and CMS and/or state review and approval processes formarketing materials.5

. . .May Create Challenges forStakeholders States: Difficult to monitor inconsistent requirementsfor health plans that cover both Medicare andMedicaid benefits Health plans: Must comply with multiple andsometimes conflicting requirements between the twoprograms Medicare-Medicaid enrollees: Must navigate separatemarketing and educational materials for each program,even if the benefits are offered through a single healthplan6

State Interaction with MedicareMarketing Activities MA open enrollment: October 15-December 7th MAOs (and MMPs after the first year of the demonstration intheir state) may begin marketing on Oct 1 CMS sends “Medicare and You” handbook to all beneficiaries Special Enrollment Period (SEP) Opportunities for states to work with D-SNPs Can encourage Medicare-Medicaid beneficiaries to enroll in DSNPs that promote alignment Include Medicaid benefits in Evidence of Coverage (EOC)document Apply other state Medicaid requirements to plans’ activities7

Use of D-SNP Contracts to IncreaseAlignment of Marketing Practices States may include provisions related to marketingin D-SNPs contracts; for example: Submit marketing materials for state review prior to CMSreview and approval or public distribution; Submit an annual outreach plan to the state and/or CMSfor approval; Restrict or prohibit plans from using any eligibility orenrollment information provided by the state formarketing materials or activities; and/or Ensure marketing materials meet cultural sensitivitystandards.8

Joint Marketing Approach for FinancialAlignment Demonstrations CMS and states pursuing capitated financialalignment demonstrations develop a single set ofmarketing rules for MMPs State-specific MMP marketing guidance documents MMG is the foundation; states tweak certain elements to fittheir program Beneficiary protections must be at least as beneficiaryfavorable as under Medicare Joint marketing materials review process in Health PlanManagement System (HPMS)9

Examples of State-Specific MarketingRequirements for MMPs Translation of materials into “prevalent languages”if more beneficiary-friendly than MMGrequirements Timeline for beneficiary receipt of materialsdepending on enrollment mechanism (e.g., opt-invs. passive enrollment ) Restrictions on marketing other lines of business inMMP materials Prohibitions on use of independent or planemployed brokers (i.e., related MMG provisions donot apply to MMPs)10

Templates for Integrated MarketingMaterials States can use and tailor templates for integratedmarketing materials: Single identification card for both programsMember handbookSummary of benefits with all servicesCombined provider/pharmacy directories for all providersAnnual notice of change (ANOC) to current beneficiariesIntegrated formularyIntegrated denial notice11

Resources Medicare Marketing Guidelines: eMarketing/FinalPartCMarketingGuidelines.html State specific marketing guidelines for the financial alignmentdemonstrations: nformationandGuidanceforPlans.html Moving Toward Integrated Marketing Rules and Practices for Medicare andMedicaid Managed Care g.pdf12

One Care: MassHealth plus MedicareA Review of Coordinated MarketingStrategies and Experiences in theMassachusetts Medicare-MedicaidProgramOctober 23, 2014Derek TymonMassHealth One Care Contract Manager

Contents Background Development of the Joint Review Process Plan Engagement 2014 Preparation, Experiences, and Lessons Learned 2015 Preparation, Experiences, and Lessons Learned Statistics to Date Key Take-Away Tips14

Background The Massachusetts Medicaid program operates under the name“MassHealth.” The duals demonstration is called “One Care.” In August of 2012, the Massachusetts Executive Office of Health andHuman Services (EOHHS) signed the Demonstration to Integrate Carefor Dual Eligible Beneficiaries MOU with CMS. MassHealth issued and completed a competitive procurement to selectOne Care Plans. 3-way contracts were executed with MassHealth, CMS, and a total of 3Massachusetts-based health plans in the Summer of 2013. The Readiness Review process ran from Fall of 2012 to Fall of 2013. Plans went live on 10/1/13 (the first effective enrollment date). As of 10/1/14, the demonstration has 17,465 members enrolled.15

Development of the Joint Review Process:Creation of the 2013 and 2014 MarketingMaterials Drafted by the CMS Medicare Medicaid Coordination Office (MMCO) Jointly edited by CMS and MassHealth (policy, legal, providers andplans units) to include state-specific policy and language Questions we considered– Which material do we want to review? (were there materials codedas “file and use” that MassHealth would prefer to review and approveprior to use?)– What is a reasonable timeframe for review? (10 days with a model,45 days without?)– Were there categories listed for all MMP documents? Other resources– Current MassHealth Managed Care Organization marketing reviewpolicy– CMS Medicare Marketing Guidelines16

Development of the Joint Review Process:Marketing Codes and Outcome Examples Simultaneous to the materials development, CMS and MassHealth reviewedan initial list of MMP marketing codes and made changes as appropriate toreflect MassHealth’s specific needs.– Non-Part D Claims/Org Determinations/Appeals/Grievances MassHealth and CMS agreed on the creation of new codes for nonPart D services (Joint CMS and MassHealth-Review)– Part D Related Documents MassHealth deferred to CMS expertise regarding review of mostPart-D items (CMS-Only Review)– Advertising such as Newspaper, Radio, and Billboards MassHealth chose to review these items to be in-line with currentMassHealth MCO requirements (State-Only Review)– Direct Mail Pieces CMS permitted direct mail but MassHealth prohibited it. Jointdiscussions resulted in approval of Direct Mail for One Care (StateOnly Review)17

Development of the Joint Review Process:Building RelationshipsDeveloping a Relationship between MassHealth/CMS MarketingReviewers Identified Key Contact and primary reviewers for MassHealth andCMS Boston Regional Office Held a face-to-face “meet and greet” between the MassHealthmarketing review team and the CMS Boston Regional Officemarketing review team Side-by-side walkthrough/review of the HPMS system Side-by-side “test” of the submitted material review process Ad hoc email/phone communication as well as weekly meetingsthrough early 201418

Development of the Joint Review Process:Building Relationships (cont’d)Developing a Coordinated Material Review Process for IntegratedMaterials Development of MassHealth/CMS protocol for how Dual-Reviewmaterials are processed through respective agencies and HPMSdeterminations are made When possible, MassHealth and CMS provide integrated commentson Disapproved materials Should dispositions be mismatched (ex. MassHealth approves andCMS Disapproves) the other side will respectfully Disapprove as well(to prevent the material from entering a state of limbo in HPMS) MassHealth and CMS marketing reviewers keep in close contactthroughout the process19

Development of the Joint Review Process:Building Relationships (cont’d)Developing a Relationship with Plans’ Operations/Marketing Teams MassHealth and CMS reviewers held a meeting with each plan tojointly introduce the team and the review process Bi-directional key contact identification Ad-Hoc emails to all One Care Plans with updated informationregarding material review process or clarifications in marketingcodes/rules Periodic check-in calls with each One Care Plan20

The Year One Marketing Review(2013 and 2014 Materials)ExperienceDuring Year One preparation: Plans frequently contacted MassHealth/CMS with questions aroundmarketing material templates Many pieces were submitted without required disclaimers or othermandatory elements Plans struggled with completion of all fields in the Provider Directorytemplate Plans’ 3rd party translation vendors took longer than anticipated toproduce translated documents Plans were delayed in their release of some English and/or Spanishdocuments The Federal Government shutdown added an extra complication21

The Year One Marketing Review:Lessons LearnedBy the end of Year One material submission, it was clear: Open lines of communication between MassHealth, CMS, and the plans arecritical to a smooth process Plans needed time to get accustomed to unique MMP Marketingrequirements Earlier release of the marketing material templates by MassHealth/CMSwould be very beneficial Plans should have the opportunity to recommend changes to marketingmaterial templates for the coming year Giving plans the ability to request “Priority Review” of submitted materialscould yield great benefits The MassHealth/CMS team could take a more proactive approach in trackingthat plans have submitted required materials to HPMS and plans areprepared to release the materials (on the web and/or in print) by requireddeadlines22

Year Two Marketing Review(2015 Materials)PreparationBased on our Year One lessons: MassHealth and CMS marketing reviewers kept track of consumer feedbackon Year One marketing material templates MassHealth and CMS marketing reviewers solicited plan feedback on YearOne marketing templates in designing Year Two marketing materialtemplates Consumer and plan feedback informed the final Year Two marketing materialtemplates MassHealth and CMS worked to release the final Year Two templates asearly as possible to plans A tracking tool was devised in order to keep tabs on the status of each plan’smandatory Year Two marketing materials Plans were allowed to request a “Priority Review” of marketing materials inorder to better meet printing and translation deadlines23

Year Two Marketing ReviewExperience and Lessons Learned Plans understood the need for the new marketing material tracking tool andprovided the information needed to complete it The tracking tool elicited productive conversations with each health planaround their planning for Year Two marketing and timely receipt of membermaterials Plans raised fewer questions around the templates, as they had already beenprovided with an opportunity to suggest changes for Year Two Plans responsibly utilized the “Priority Review” option, and were veryappreciative of itResults All 3 plans successfully released their required marketing materials onlineand in print by October 1st (with the exception of one document’s Spanishtranslation) Fewer instances of missing disclaimers and other errors, meaning morematerials were approved upon first review24

Statistics to Date As of 10/1/14, a total of 643 materials have been received All materials have been reviewed within the allotted amount of time25

Key Take-Away Tips Open channels for ad-hoc communication and coordination betweenthe state and CMS are critical Build working relationships with key marketing contacts at each plan Consider plan and consumer feedback around marketing materialtemplates Proactively work with plans to ensure they are on track to meetmarketing deadlines Consider new ideas that can enhance the process (ex. offeringPriority Review)26

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Questions andDiscussion28

About ICRC Established by CMS to advance integrated care models forMedicare-Medicaid enrollees and other Medicaid beneficiarieswith high costs and high needs ICRC provides technical assistance (TA) to states, coordinatedby Mathematica Policy Research and the Center for HealthCare Strategies Visit to submit aTA request and/or download resources, including briefs andpractical tools to help address implementation, design, andpolicy challenges Send additional questions to: [email protected]

MassHealth and CMS agreed on the creation of new codes for non-Part D services (Joint CMS and MassHealth-Review) –Part D Related Documents MassHealth deferred to CMS expertise regarding review of most Part-D items (CMS-Only Revi