The leaves are beginning to turn colors and Medicare open enrollment for 2023 is upon us…. Meaning, Medicare Advantage planning for 2024 is right around the corner – YES, 2014!
While current Medicare Advantage (MA) plans are preparing for open enrollment to begin, future planning for the upcoming 2024 initial and service area expansions are also at the forefront. Based on prior Center for Medicare and Medicaid Services (CMS) calendar years, the notice of intent to apply (NOIA) for 2024 will take place from November 2022 -January 2023. While that may seem far away for some, we all know how long it takes to strategically plan for growth, complete the paperwork, and get everything submitted on time. Here’s the deal – start early, plan ahead, and make sure all your ducks (or squirrels if that’s what you have) are aligned. Reminder that any late filings for the NOIA will result in a denial of the application.
If you are a new market entrant for a Medicare Advantage Organization (MAO) or Part C 1876 Cost Plan, there is a lot to consider prior to submitting your NOIA and subsequent application. For example, what kind of plan do you intend to offer: a Coordinated Care Plan, a Regional Preferred Provider Organization (RPPO), a Special Needs Plan (SNP), or maybe you want to serve as an Employer Group Wavier Plan (EGWP). Also for consideration are the benefits you plan to include in addition to what standard Medicare requires under Part A and Part B benefits. Benefits like vision, dental, wellness coverage, or hearing services are often offered to enhance beneficiary coverage. Part D, or prescription drug coverage, can be added as a private fee-for-service (PFFS) formulary or through a PBM. All these enhanced benefits make a new MA plan attractive to beneficiaries and increase the likelihood of beneficiary selection during open enrollment.
If you are an existing MA plan that is planning to expand your MA service area, offer new MA products, or plan to submit a PFFS network transition application, you must also complete a nonbinding NOIA. Any expansion of services or service areas will require additional steps to get your plan approved and ready for the 2024 plan year. If the plan is making changes to the current offering in any way, rest assured that there will be planning and other work to do to support those changes.
Now let’s move into considerations for both new and expanding plans – and submission of your provider network file through the Health Plan Management System (HPMS). Requirements for network adequacy are fluid and meeting them are a challenge. The health service delivery (HSD) tables provide an overview of what network adequacy must look like in any one service area – by county and provider type. However, meeting the number of providers required and time and distance standards, as laid out in the HSD tables, based on the time allotted is tough. Plan applicants are required to complete their provider contracting by the early spring for a plan year starting the following January (Think January 2024!). This nearly eight-month delta can limit MA expansion. Each spring, dozens of MA applicants must cut their preferred service areas because they are unable to finalize their provider contracts by CMS’s deadline. Remember those squirrels?
Providers are also capricious. An MAO or Cost Plan’s need to contract is not the provider or hospital’s problem or priority. While providers want to do the right thing, their timeline does not always align with a plan’s timeline – hence the difficulty in completing and meeting network adequacy deadlines. Without a signed agreement on file, plans cannot include that provider with their required HSD table submission which results in network gaps. With all that being said, the best advice is don’t wait. Provider contracting and negotiating takes time. Plan for these activities at a minimum of six-months in advance when possible. If you don’t have internal resources, look outside your organization for a respected provider network development and consulting firm. The use of external resources for contracting and credentialing has come a long way for MA Plans – and it works!
In summary, there is a lot to think about in the MA space for new and existing plans. Make a plan now! Invite key people to the table and have discussions about service areas, benefit enhancements, innovations, technologies to be used, and the provider landscape in the market. Strategic planning doesn’t happen overnight, and neither will your process to enter or expand the Medicare Advantage marketplace. Those squirrels do require some training….
For more information on the Medicare Advantage Application process, visit: To get help with strategic planning, provider network contracting, or Medicare Advantage readiness, reach out to ARC Healthcare, LLC. You can visit our website at: https://www.cms.gov/medicare/medicare-advantage/medicareadvantageapps
To get help with strategic planning, provider network contracting, or Medicare Advantage readiness, reach out to ARC Healthcare, LLC. You can visit our website at: “https://myarchealthcare.com/”