Time Is running Out To Change
Medicare Advantage Prescription Drug Plans
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The initial enrollment period for joining a Medicare Part D drug plan ended on May 15th, and with it ended the opportunity for most people who enrolled in a stand-alone prescription drug plan (PDP) to make a one-time change. Unless they are eligible for a Special Enrollment Period (SEP), PDP enrollees are locked in to their plan choice now - meaning they cannot change plans or simply disenroll from their current plan - until the Annual Enrollment Period (AEP) which begins on November 15 and runs through December 31. Changes made during the annual enrollment period take effect on January 1 of the following year.
Individuals in Medicare Advantage (MA) plans, however, have another two weeks - until June 30 - to change to a different plan. That is because, at least for 2006, the Open Enrollment Period (OEP) for making changes to MA enrollment runs through June 30.
The OEP is separate from the Annual Enrollment Period, which coincides with the Annual Enrollment Period for PDPs and runs from November 15th through December 31. The OEP provides a second opportunity for MA enrollees to make one change to their plan choice.
While the OEP for 2006 runs from January 1 through June 30 in 2006, starting in 2007 the OEP will run for the first three months of each year, January through March. In other words, individuals may change or enroll in an MA plan during the Annual Enrollment Period in 2006. They may then change MA plans once from January through March, 2007. Unlike during the Annual Enrollment Period, MA plans are not required to be open during the OEP to accept new enrollees.
What Changes Can Be Made?
MA plans include health maintenance organizations (HMOs), local and regional preferred provider organizations (PPOs), and private fee-for-service plans (PFFSPs). Most HMOs and PPOs offer prescription drug coverage. PFFSPs are not required to offer drug coverage, although some do. MA plans that offer drug coverage are referred to as Medicare Advantage plans with drug coverage (MA-PDs).
The distinction between an MA-PD and an MA plan is critical, and not only for the difference in benefits provided. Someone enrolled in an MA-PD may only change to another MA-PD during the OEP. Someone enrolled in an MA plan may only change to another MA plan. In other words, someone in an MA plan who decides in June that she now wants drug coverage cannot change to a Medicare Advantage plan that provides drug coverage. She must wait to change until the next Annual Enrollment Period.
All individuals in MA plans may also return to the original Medicare program during the Open Enrollment Period. Those who are in an MA-PD plan and who return to original Medicare must enroll in a PDP. They have a Special Enrollment Period that allows them to make one PDP election; they may not change PDPs until the next Annual Enrollment Period. Individuals who are in an MA plan may return to Original Medicare during the OEP, but they cannot enroll in a PDP until the next Annual Enrollment Period.
The OEP also provides an opportunity for individuals in original Medicare to enroll in an MA plan. Those who have a PDP must enroll in an MA-PD. Those who do not have drug coverage are limited to enrolling in an MA plan.
How Can A Beneficiary Change Enrollment?
An individual can disenroll from an MA or MA-PD and be returned to original Medicare by:
An individual who wants to change to a different MA or MA-PD may also:
The MA or MA-PD is supposed to send a letter to enrollees who leave to return to original Medicare. Someone who changes to a different MA or MA-PD should get a letter from the new plan.
Coverage under the new plan, or under original Medicare and a PDP, is supposed to start the month after the change is made. This new coverage should begin in July for individuals who exercise their option to change plans during June of this year. It is best to switch plans before the 10th of the month in order to help ensure that the switch will be effective beginning the next month. Individuals who change plans and who experience problems should contact the regional office of the Centers for Medicare & Medicaid Services (CMS) right away.
Important Information For People With Employer Or Union-Sponsored Drug Coverage
June marks the end of the fiscal year for many employers, and it is a time when employers and unions may choose to change their health benefits for retirees and active workers. Thus, some employer or union-sponsored drug coverage that was deemed to be creditable, i.e., as good as Medicare, last year may no longer be creditable coverage. Employers are supposed to notify their employees and retirees of the status of their drug coverage.
Individuals who experience an involuntary loss of creditable coverage have a Special Enrollment Period in which they may enroll in a PDP. According to the CMS Eligibility, Enrollment and Disenrollment Guidance, the SEP begins with the month the individuals are advised of the loss of creditable coverage, and ends 60 days after the loss or notice of the loss, whichever is later. Individuals who are notified in June that their creditable drug coverage ends June 30 will therefore have 60 days after June 30 to choose and enroll in a Part D plan. If they fail to enroll in a plan during their SEP, they must wait until the Annual Enrollment Period (November 15 – December 31) to enroll in a PDP or MA-PD, and they will have to pay a late penalty for the months they were without drug coverage.
Summary of Enrollment Periods
Annual Enrollment Period for stand-alone prescription drug plans and all Medicare Advantage plans:
· November 15 - December 31;
· Changes effective January 1;
· All Medicare beneficiaries are free to choose among all available options;
· MA plans required to be open to enrollment.
Open Enrollment Period for Medicare Advantage plans with and without drug coverage:
· For 2006: January 1 – June 30;
· For 2007 and beyond: January 1 – March 31;
· MA enrollees may change plan status once during OEP;
· Traditional Medicare Beneficiaries may opt for an MA plan during OEP;
· Institutionalized individuals may make an unlimited number of changes during OEP;
· MA plans NOT required to be open to enrollment.
Examples of Special Election Periods:
· Individuals who are eligible for Medicare and Medicaid for as long as they receive Medicaid benefits;
· Individuals who experience an involuntary loss of creditable coverage - begins with the month the individuals are advised of the loss of creditable coverage, and ends 60 days after the loss or notice of the loss, whichever is later;
· Changes may be made at any time during the SEP.
Copyright © Center for Medicare Advocacy, Inc. 05/05/2008