Updated Medicare Cost Plan Enrollment & Disenrollment Instructions

Relevant to: PDP, Enrollment and Payment Systems, PACE, Part D

Each week, we scan the latest CMS memos to find the most important ones that apply for PACE programs. Below is a summary of what you need to know.

Disclaimer: The content provided on this site is a summary for informational purposes only, and Grane PBM, Inc. assumes no liability for any errors or omissions in the site’s content. The information does not constitute legal or regulatory advice or replace the original CMS memo. Readers are advised to consult the CMS memo in its entirety and to verify information independently before making any decisions based on this information.

Click here to read the complete memo from CMS.

Introduction

The Centers for Medicare & Medicaid Services (CMS) has released the final version of Chapter 17D of the Medicare Managed Care Manual, detailing crucial updates effective January 1, 2025. These revisions are aligned with regulatory changes from CMS-4201-F3 and CMS-4205 and impact Special Election Periods for dually eligible individuals among others. Key updates include changes to enrollment and disenrollment guidance and revised model enrollment forms to align with Medicare Advantage and Part D standards.

Key Dates and Deadlines

  • Memo Date: January 8, 2025
  • Effective Date of Rule: January 1, 2025
  • End Date for Coverage Gap Phase of Part D Benefit: December 31, 2024

PACE Compliance

This memo is relevant to PACE programs as it describes updates to enrollment and disenrollment instructions, which could affect how PACE organizations operate under the revised rules. It is essential for PACE organizations to understand updates to the Special Election Periods especially if they cater to dually eligible and low-income subsidy (LIS) eligible individuals.

PACE organizations must ensure compliance with the following:

1. Review and understand changes made to the Special Election Period for dually eligible and LIS eligible individuals. These modifications could influence how and when participants can enroll or disenroll from their programs.

2. Update any model enrollment forms currently in use to align with the new language as prescribed in the MA and Part D model forms to ensure compliance with the latest requirements.

3. Be aware of the removal of language concerning the coverage gap phase of the Part D benefit and adjust any internal or external communications accordingly.

4. Stay informed about the removal of outdated times for contacting the Social Security Administration to provide accurate guidance to beneficiaries.

The guidance is effective immediately, thus requiring prompt attention and action to these changes.

Required Actions

The memo from the Department of Health & Human Services provides important updates on Medicare Cost Plan Enrollment and Disenrollment Instructions as of January 1, 2025. The document highlights the latest version of Chapter 17D of the Medicare Managed Care Manual. Below are the primary actions that should be taken in response to these updates:

1. Review the final version of Chapter 17D of the Medicare Managed Care Manual to understand the new guidelines and ensure compliance with the updated Special Election Period for dually eligible individuals and other low-income subsidy-eligible individuals.

2. Update organizational processes and documentation to align with the updated guidance, including revising model enrollment forms to ensure they match the updated MA and Part D standards, and removing outdated information about the Part D coverage gap phase and outdated Social Security Administration contact times.

3. Ensure immediate implementation of the new guidance and address any clarification questions by contacting the provided LMI Mailbox link for support.

FAQs

  • “What are the key updates in the Medicare Cost Plan Enrollment and Disenrollment Instructions?”
  • “How do the changes affect dually eligible individuals and those eligible for low-income subsidies?”
  • “What revisions have been made to model enrollment forms in the updated guidelines?”
  • “Why has language about the coverage gap phase been removed from exhibits?”
  • “Where can I access the updated Chapter 17D of the Medicare Managed Care Manual?”

Click here to read the complete memo from CMS.

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