2018 Medicare Marketing Guidelines Impose Minimal New Website Compliance Hurdles

Posted by Alan Mittermaier

The delayed posting of the CY 2018 Medicare Marketing Guidelines on July 20th reveals only modest changes pertaining to Medicare Advantage/Part D website compliance.  Areas involving new and existing compliance clarification include the following:

60.4 – Formulary and Formulary Change Notice Requirements  (pp. 27-28)
60.4.3 – Changes to Printed and Posted Formularies  (p.28)

Comment:  Both of the above clarifications favor document eDelivery opt-in for plan members.

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100.4 – Online Formulary, Utilization Management (UM), and Notice Requirements (p.71)

Comment:  Previous online notification provisions become “must” requirements.

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100.7 – Third-Party Websites (pp.73-74)

Comment:  Includes new guidelines specifically for third-party websites defined as sites not owned by Plan/Part D sponsors, but by companies with whom Plan/Part D sponsors have contracts for the purpose of selling or promoting Medicare products.

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Contact HealthMetrix Research president Alan Mittermaier for additional guidance related to 2018 website compliance and MedicareWebWatch evidence-based build-out strategies.

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What Prevents Medicare Advantage Plans from Offering 5-Star Websites? [Part 2]

Posted by Alan Mittermaier

April 24, 2017

While only a handful of 2017 Medicare Advantage plans can boast 5-Star CMS overall performance ratings (total of 14 by my count), every plan is capable of building a 5-Star website for their key target audiences — plan members, caregivers, prospects.  Yet, after mapping Medicare plan websites annually since 2009 for the MedicareWebWatch project, it is still disappointing to observe the low engagement experience among so many websites.

The new 2017 MedicareWebWatch project findings breakout 13 “Benchmark” or 5-Star websites plus another 20 “Distinguished” websites.  These highly-rated websites are  not exclusively among the largest Medicare Advantage players.  Many mid-size plan websites are among the highest rated as well.  The common thread among these “Benchmark” and  “Distinguished” websites is their commitment to elevating the user engagement experience.

As a Medicare Advantage plan member and 67 year old boomer, I have a first-hand perspective both from navigating all 147 Medicare plan websites recently and from my daily use of an array of websites for personal purposes — news, banking, travel, purchases.  Below are 2 simple bolt-on content features that every Medicare plan website should provide for enhancing the user engagement experience — with examples.

1. Medical topic and drug information — Only 46% (67 of 147) of sites provide content or links to trusted resources for users seeking information on medical topics or drugs.  Pew internet research has consistently reported that among adult internet users, searching for medical information is one of the highest reported activities in terms of time spent .  CommunityCare and  Peoples Health (via StayWell) provide the best examples.  By far the easiest external content link setup is the free MedLine Plus-Senior Health (National Library of Medicine).
2. Medicare national coverage determinations — Just short of 29% (42 of 147) of sites provide details related to CMS national coverage determinations (NCDs) for new diagnostic, therapeutic, treatment services.  Interestingly, a super-majority of plans are non-compliant with informing members when CMS issues such mid-year determinations — see 2017 Medicare Marketing Guidelines (p. 47).  Among compliant plans, check CDPHP and Rocky Mountain Health Plan.  NCD updates and details are available at CMS.gov .

(This is the second in a series highlighting the 2017 MedicareWebWatch project findings)

Kaiser Permanente Repeats as #1 Medicare Website in 2017 “Madness in March” Results

Posted by Alan Mittermaier

Congratulations to Kaiser Permanente and its Medicare plan website, Medicare.KaiserPermanente.org, on repeating as winner of the 2017 “Madness in March” competition among 147 Medicare plan websites surveyed by HealthMetrix Research Inc.  This is the sixth year since 2009 that Medicare.KaiserPermanente.org has been recognized as the overall top Medicare website.   Kaiser Permanente’s website advanced through five rounds of matchups that featured 32 top-scoring Medicare websites.  The complete “Madness in March” bracket results can be viewed at — 2017 MWW Madness bracket FINAL

The annual independent MedicareWebWatch project tracked 50 common and advanced features across four categories — content, member connectivity, design, transparency.   HealthMetrix Research recognized a total of 13 “benchmark” and 20 “distinguished” Medicare plan websites in a February 22 PRNewswire release.  See additional details about MedicareWebWatch website certification at – www.MedicareWebWatch.com

Give Your Medicare Advantage Plan Website a Thorough Independent Annual Review

March Madness is here which means an invitation to join Alan Mittermaier for a one-hour consultation webinar highlighting the 2015 MedicareWebWatch website findings along with MedicareWebWatch certification details for your organization. Included are actionable build-out insights for how your organization’s Medicare Advantage website can become more relevant and ready to meet the growing expectations of plan members, age-ins and caregivers. The webinar also covers best practices from industry-leading websites recognized for “Excellence in Website Content, Connectivity, Design and Transparency”.

HealthMetrix Research President Alan Mittermaier has an extensive background from advising over 60 Medicare Advantage sponsors and research organizations including Mathematica Policy Research, National Council on Aging (NCOA) and Research Triangle International. Mr. Mittermaier also offers his unique perspective as a recent Medicare Advantage plan enrollee.

Each webinar will accommodate up to 20 attendees and will be recorded for your organization’s internal use. Note: The registration fee ($500) can be credited towards the 2015 MedicareWebWatch certification licensing fee.  Click here to register today!

HealthMetrix Research Finds Medicare Advantage Plan Star Ratings Need an Extra Dose of Transparency

Medicare beneficiaries selecting their 2015 Medicare coverage will be hard pressed to determine which Medicare Advantage (Part C) and Medicare drug (Part D) plans to consider for enrollment based on published performance star ratings.  Recently reported Government Accounting Office (GAO) findings concluded that Medicare websites generally fall short on giving consumers basic decision-support tools.  The GAO study did not address the transparency issues associated with CMS performance star ratings for the popular Medicare Advantage and Medicare drug plans.1,2The Centers for Medicare and Medicaid Services (CMS) launched the plan performance star ratings for the 2012 enrollment year and updates star ratings each October on the Medicare.gov Plan Finder website.  The recently released 2015 star ratings consist of 33 underlying measures for Part C plans and 13 underlying measures for Part D plans.  The 46 total underlying measures span five broad categories – 1) outcomes; 2) intermediate outcomes; 3) patient experience; 4) access; 5) process. After assigning weighting factors, each Part C and Part D plan receives a 1 to 5 star overall or aggregate rating.  Exceptions include plans too new or with too few enrollees to establish meaningful ratings.3While performance ratings may not be of vital interest to all beneficiaries, neither CMS nor plan sponsors have delivered high-level transparency for those consumers seeking to make informed choices about their Medicare coverage.  The following recommendations represent positive steps to increase the transparency and value for future performance star ratings. 1.   Identify the star rating year with the performance data collection time frame.  Consumers are likely unaware that the recently released 2015 performance ratings are lagging performance indicators generated from data collected during 2013 and early 2014.  According to CMS, 32 of the total 46 underlying 2015 performance measures are from 2013 reported data,4 yet only two of the 46 underlying measures displayed on the Medicare.gov Plan Finder website identify the data collection occurring during 2013.  Better data collection time-frame captioning along with a disclaimer are needed, e.g, “2014 performance ratings are based on plan data from 1/1/2013 through 6/30/2014 and do not reflect current or future performance.” 2.   Provide year-over-year (YoY) rating changes on Medicare.gov Plan Finder to allow consumers to view whether performance ratings improved (⇑), declined (⇓), or remained unchanged (⇔).  The Medicare.gov Plan Finder ratings format only allows consumers to toggle from the current year’s ratings page to the previous year’s ratings page.  A more valuable consumer-friendly format should include change indicators alongside each overall and underlying star rating on all pages where ratings are displayed. 3.   Include national average rating comparisons for each plan’s performance measures.  The Medicare.gov Plan Finder allows consumers to compare performance ratings only among Part C and Part D plans available in each consumer’s zip code service area.  A valuable high-level comparison can be displayed by overlaying the national ratings for each rating measure. 4.   Require Part C and Part D plan sponsors to display ratings for all underlying performance measures on their websites in addition to the required overall performance star rating(s).  For consumers who do not visit the Medicare.gov Plan Finder website, the other likely source for viewing performance ratings are on individual Part C and Part D plan websites.  Under current marketing regulations, CMS only requires Part C and Part D plan websites to post their current overall ratings summary.5  HealthMetrix Research found only 3 of 142 Part C plan websites voluntarily displayed 2014 detailed star ratings in addition to the required overall ratings summary this year.  The downside implication for consumers is that overall high-rated plans (4, 4.5, 5 stars) are allowed to shield from view their low-rated underlying measures (1 or 2 stars).  Specifically, limited disclosure allows a Part D drug plan in Portland, OR to boast an overall 4.5 star rating while only achieving a 2 star underlying rating for members’ rating of drug plan.  Similarly, another Part C plan in Portland, OR boasting an overall 4 star rating also earned a 1 star underlying rating for fairness in appeal decisions by independent review. Each plan’s website should display star ratings for all of the underlying performance measures preferably on a dedicated page linked to each Part C and Part D product offered.  Additionally, navigation links to access performance ratings should be prominently located on Medicare plan’s home page. Medicare beneficiaries choosing to be diligent, informed consumers deserve no less than the most robust level of transparency (full disclosure) that easily allows them to evaluate past plan performance with complete confidence. Note: HealthMetrix Research president Alan Mittermaier has followed the Medicare managed care industry since 1997 and recently enrolled in a 4-Star Medicare Advantage-Part D drug plan. For additional background, contact Alan Mittermaier – Alan@healthmetrixresearch.com Sources 1 “Feds Fall Short on Medicare Websites”, Associated Press, November 18, 2014 2 “Health Care Transparency: Actions Needed to Improve Cost and Quality Information for Consumers”, GAO, October 2014 3 “Fact Sheet – 2015 Star Ratings”, CMS, October 7, 2014 4 “Medicare 2015 Part C & D Star Ratings Technical Notes”, CMS, October 3, 2014 5 “2015 Medicare Marketing Guidelines”, CMS, June 13, 2014 Visit the MedicareWebWatch related 7/18/2014 blog posting – Medicare Advantage Plan Websites Need User-Friendly Upgrades Also visit PRNewswire for recent HealthMetrix Research news releases: HealthMetrix Research Selects 2015 Medicare Advantage Plans for Exceptional Benefit Value & Overall  Performance – 10/15/14 HealthMetrix Research Selects Outstanding Medicare Advantage Websites for 2014 MedicareWebWatch Certification – 2/10/2014

2014 CMS Star Ratings Transparency Still Lacking

Among the 140 Medicare Advantage plan websites, only the three sponsors shown below  have chosen to post one or more of the 5 performance category star ratings in addition to the required overall 2014 star ratings.  While not required by CMS Medicare Marketing Guidelines, website visitors benefit by the full disclosure of all 5 performance categories.

See Blue Cross Blue Shield of Massachusetts

Overall Plan Rating      4.5 Stars out of 5

Customer Service     5 Stars out of 5

See Martin’s Point HealthCare

Customer Service

Overall Rating of Health Care Quality

Members’ Overall Rating of Health Plan

See Tufts Medicare Preferred

Overall Score  

Staying Healthy (screening, tests, vaccines)    5 stars

Managing chronic (long-term) conditions    4 stars

Member experience with the health plan   5 stars

Member complaints, problems getting services, and improvements in the health plan’s performance    4 stars 

Health plan’s customer service    4 stars 

 

Staying Healthy (screenings, tests, and vaccines)

Staying Healthy (screenings, tests, and vaccines)

Overall ScoreFor plans covering health services, the overall score for quality of those services covers 45 different topics in 5 categories:5 starsStaying Healthy (screenings, tests, and vaccines)Includes how often members got various screening tests, vaccines, and other check-ups that help them stay healthy.4 starsManaging chronic (long-term) conditionsIncludes how often members with different conditions got certain tests and treatments that help them manage their condition.5 starsMember experience with the health planIncludes ratings of member satisfaction with the plan.4 starsMember complaints, problems getting services, and improvement in the health plan’s performanceIncludes how often Medicare found problems with the plan and how often members filed complaints against the plan and choose to leave the plan. Includes how much the plan’s performance has improved (if at all) over the last two years.4 starsHealth plan customer serviceIncludes how well the plan handles calls from members, makes decisions about member appeals for health coverage, and handles new enrollment requests in a timely way.- See more at: http://www.tuftsmedicarepreferred.org/medicare-star-rating#sthash.bvrdI55N.dpuf

Overall ScoreFor plans covering health services, the overall score for quality of those services covers 45 different topics in 5 categories:5 starsStaying Healthy (screenings, tests, and vaccines)Includes how often members got various screening tests, vaccines, and other check-ups that help them stay healthy.4 starsManaging chronic (long-term) conditionsIncludes how often members with different conditions got certain tests and treatments that help them manage their condition.5 starsMember experience with the health planIncludes ratings of member satisfaction with the plan.4 starsMember complaints, problems getting services, and improvement in the health plan’s performanceIncludes how often Medicare found problems with the plan and how often members filed complaints against the plan and choose to leave the plan. Includes how much the plan’s performance has improved (if at all) over the last two years.4 starsHealth plan customer serviceIncludes how well the plan handles calls from members, makes decisions about member appeals for health coverage, and handles new enrollment requests in a timely way.- See more at: http://www.tuftsmedicarepreferred.org/medicare-star-rating#sthash.bvrdI55N.dpuf

Overall ScoreFor plans covering health services, the overall score for quality of those services covers 45 different topics in 5 categories:5 starsStaying Healthy (screenings, tests, and vaccines)Includes how often members got various screening tests, vaccines, and other check-ups that help them stay healthy.4 starsManaging chronic (long-term) conditionsIncludes how often members with different conditions got certain tests and treatments that help them manage their condition.5 starsMember experience with the health planIncludes ratings of member satisfaction with the plan.4 starsMember complaints, problems getting services, and improvement in the health plan’s performanceIncludes how often Medicare found problems with the plan and how often members filed complaints against the plan and choose to leave the plan. Includes how much the plan’s performance has improved (if at all) over the last two years.4 starsHealth plan customer serviceIncludes how well the plan handles calls from members, makes decisions about member appeals for health coverage, and handles new enrollment requests in a timely way.- See more at: http://www.tuftsmedicarepreferred.org/medicare-star-rating#sthash.bvrdI55N.dpuf

Medicare website accessibility remains weak

HealthMetrix Research includes diagnostic testing for website accessibility (Section 508 & WCAG standards) in its MedicareWebWatch annual certification survey.  Based on the recent  testing conducted in February, only 5 of 133 websites (4%) passed the SortSite diagnostic testing for accessibility.  Congratulations to these organizations who have done the necessary diligence to ensure maximum accessibility for all website visitors.

Disapproved Websites Subject to Blackout During 10-Day Correction Period

According to the 2013 Medicare Marketing Guidelines released April 2, 2012 –

90.2.3 – Submission of Websites for Review  …”If a plan sponsor’s website is initially disapproved, they must resubmit the corrected website for review within 10 business days of the disapproval date. During this time, the plan sponsor must take down this web site so it is not viewable to the public.”

Section 508 Accessibility Compliance Lagging

HealthMetrix Research continues to question both the compliance with and enforcement of Section 508 website accessibility as required by the Medicare Marketing Guidelines.  The lack of Medicare website accessibility was initially brought to CMS attention in May 2010 when HealthMetrix Research’s MedicareWebWatch Section 508 compliance testing revealed a 79% failure rate.  The latest MedicareWebWatch testing completed in January indicates modest improvement with 57% of Medicare plan home pages still failing Section 508 compliance testing.

The most common cause of failure is 508 Standards, Section 1194.22, (a) A text equivalent for every non-text element shall be provided (e.g., via “alt”, “longdesc”, or in element content).

How transparent are plan Star ratings?

Good luck finding Star ratings based on the latest MedicareWebWatch website mapping analysis conducted in early January.  HealthMetrix Research looked for Star rating pages and the HPMS-generated documents on 137 websites with mixed results.
> Unable to locate CMS Star summary   = 29  (21%)
> Google or site search required for link  = 16  (12%)

After spending an average of 45 minutes mapping each Medicare website,HealthMetrix Research found transparency woefully lacking for at least 33% of the total 137 websites.  CMS only requires posting the Star ratings (Refer to 2012 Medicare Marketing Guidelines pp. 27-28), however, provides no guidance for site location or accessibility by users.

The Star ratings placement varied widely but most typically were found linked or posted on one or more of these pages —
> Member resources/communications
> Plan benefits
> Plan documents
> Corporate communications
> Awards and recognition