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Medicare AdvantageFuture of MA Special Needs Plans After 2008 Is in Doubt Reprinted from the May 2007 issue of MEDICARE PART D COMPLIANCE NEWS, a monthly newsletter on implementation problems and compliance strategies for the new Medicare drug benefit. The provision in the 2003 Medicare reform law creating Special Needs Plans (SNPs) is set to expire at the end of 2008, and there is no guarantee the program will continue. That means the future of a major Part D product is in doubt. Abby Block, director of the Center for Beneficiary Choices at CMS, told attendees at the America's Health Insurance Plan Medicare Operations Conference in Baltimore April 23 that the provision will "sunset without [congressional] legislation" extending it. If she had to venture "a guess," Block said, "at a minimum, Congress will at least extend the program, but maybe not make it permanent." She noted that CMS is working on a required report on SNPs due to Congress in December. But it is difficult to describe the value added by the plans at this point because they are "new plans with small enrollments." "It's hard to come up with data to validate the plans," she explained. SNPs are Medicare Advantage (MA) plans for certain classes of disadvantaged beneficiaries (e.g., Medicare-Medicaid dual eligibles, institutionalized, and the chronically ill), that must include Part D coverage. John Gorman, president and CEO of Gorman Health Plan, LLC, predicted that SNPs will benefit the most from the rapid growth of MA prescription drug plans seen in 2007. There was a "huge increase" of almost 200 new SNPs between 2006 and 2007, he said, with CMS approving 471 SNPs for operation in 2007. Also, almost 800 Notices of Intent for SNPs have been filed for the 2008 contract year. Even if only one-quarter of these plans actually submitted applications, that will be 200 more SNPs in 2008, he explained. One way they can keep expanding, he suggested, is that they "can keep signing up people with a special election period" throughout the year with no lock-in to worry about. He indicated he is "now seeing" all sorts of new SNPs, such as ones for cancer patients and Alzheimer's beneficiaries. It was "intentional" on the part of CMS to leave the term 'severely chronically ill and disabled' (used to qualify Medicare beneficiaries for SNP membership) vague, Gorman suggested, "to see how the market develops." Block, on the other hand, suggested that plan sponsors "need to demonstrate that [SNPs] have value" in order to keep them going. She strongly encouraged plans to work with states to come up with integrated products for dual-eligible beneficiaries and for plans and institutions to work together to help institutionalized beneficiaries. CMS Tries to Differentiate SNPs According to Block, CMS's recent 2008 MA call letter "makes sure SNPs are differentiated from other products," such as regular MA and MA private fee-for-service plans. The call letter clarifies that for 2008 dual-eligible SNPs may exclude specific groups based on the MA organization's coordination efforts with state Medicaid agencies. CMS will approve these requests on a case-by-case basis. The agency also is planning to develop SNP quality measures to assess health outcomes (clinical, functional, and patient experiences) of enrollees in SNPs, she said. Furthermore, Jane Andrews, director of the Division of Benefits in the Medicare Advantage Group at CMS, told attendees that there have been changes to the Plan Benefit Package (PBP) with regard to SNPs. For 2008, plan sponsors must provide more detailed information, including the percentage, population and type of beneficiaries in the SNP, and whether the SNP consists of chronic or disabled beneficiaries if applicable, she explained. She added that the Summary of Benefits "has been updated to reflect appropriate cost-sharing [information] depending on the type of SNP" offered by a sponsor. For example, if a SNP consists exclusively of full dual eligibles, it may offer zero cost sharing. If the SNP has different types of dual eligibles, cost sharing must consist of a range.
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