Release of 2019 CMS Model Documents Provides Health Plans Opportunity to Replace EOC with 1 Page EOC NOTICE Form
CMS released the model documents last week, on Friday afternoon, 05/25/18. While the final CMS Marketing Guidelines have not yet been published, based on discussions with DMC consultants, and other experts, it appears from the instructional language accompanying the model documents that Plans can simply mail EOC Notices to Members, instead of EOC books, beginning with the 2019 ANOC/EOC mailings. The CMS requirement for Plans to deliver EOC books to its members is then accomplished by Plans posting the EOC documents on their websites in conjunction with the mailing of the EOC NOTICES, just as is currently done with the Provider Directories. Of course, last year, CMS also began allowing Plans to provide delivery of the formulary books through this same process (i.e. mailing formulary Notices/posting formularies on the Plan website).
This year, it appears that all ANOC documents can be mailed in a single envelope, scheduled for in-home delivery by 09/30/18 – which we believe will be comprised of the following components:
- Driver Sheet
- ANOC Cover Letter
- ANOC book
- EOC Notice
- Notice of Privacy Practices
- PPD/Formulary Notice
- Outside Envelope with the Disclaimer
The decision to include formulary and EOC books is Plan optional. We know there are some Plans that intend on mailing the formulary and EOC books to their Members; but, we thought it compelling to bring this information to your attention.
If a Plan elects to only mail formulary and EOC notices to its Members and fulfill delivery requirements electronically by posting these documents on their website, then the Plan must be ready to fulfill Member requests for these books within three business days of the Members’ request (i.e. books must mail within 3 business day; there is no delivery time requirement).
DMC can provide NEXT DAY fulfillment services for a Plan’s Member document requests. When DMC fulfills these member requests we provide corroborating documentation in the form of USPS mailing statements and appended Member data files. DMC appends the USPS IMpb barcode to the Member data files, which then provides proof as to the timing of the fulfillment (date mailed) and proof of delivery (USPS Delivery Confirmation). Plus, DMC can effectuate these mailings at Bound Printed Matter Parcel rate (standard mail/marketing mail rate), which is far less costly than whatever method might be used by Plans that are fulfilling these Member requests internally at their offices.