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In a June 2016 Weekly Alert the Center wrote about a process called “seamless conversion enrollment” used by some insurance companies that offer Medicare Advantage (MA) plans to capture enrollment among their pre-Medicare plan enrollees.  As we noted, “Medicare rules allow MA plan sponsors to ‘develop processes to provide seamless enrollment in an MA plan for newly Medicare Advantage eligible individuals who are currently enrolled in other health plans offered by the MA organization (such as commercial or Medicaid plans) at the time of their conversion to Medicare.’  MA organizations that wish to perform such ‘seamless conversion enrollments’ must obtain approval from the Centers for Medicare & Medicaid Services (CMS), and certain conditions must be met by the plan.” See Case Study: Enrolled In a Medicare Advantage Plan Without Her Knowledge Through “Seamless Conversion Enrollment” (June 1, 2016).

Although seamless conversion enrollment has been authorized by statute since the late 1990s and has been described in regulations and Medicare manuals for a number of years, neither the Center nor our partner organizations had encountered Medicare beneficiaries affected by this process until relatively recently.  Following a number of news stories and advocacy efforts on the part of the Center and some of our partners including the Medicare Rights Center, Justice in Aging and the National Council on Aging (see, e.g., the letter to CMS sent by these organizations), seamless conversion enrollment has garnered increased attention.

On October 21, 2016, the Centers for Medicare & Medicaid Services (CMS) issued a memorandum to MA plans announcing its temporary suspension on accepting any new seamless enrollment proposals.  CMS also, for the first time, released data related to seamless conversion enrollments, including a list of plans that have been approved to use the process.  With respect to MA organizations that have already been approved, CMS indicated that it will “soon issue a memorandum clarifying current policy requirements.”

The Center applauds CMS’ decision to both impose a moratorium on approving plans and issue information concerning what plans have already been approved.  Absent rescinding the authority of plans to conduct seamless conversion enrollment altogether, we urge CMS to incorporate much stronger consumer protections as outlined in the advocates’ letter above.

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