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In late July 2019, the General Accounting Office (GAO) issued a report entitled “Medicare Plan Finder: Usability Problems and Incomplete Information Create Challenges for Beneficiaries Comparing Coverage Options” (GAO-19-627).

In short, according to the Report, “[t]he Medicare Plan Finder (MPF) website—a primary resource for comparing Medicare coverage options—is difficult for beneficiaries to use and provides incomplete information, according to stakeholders and research studies.” The Center for Medicare Advocacy was among the stakeholders interviewed for this Report.

As noted by House Ways & Means Chairman Richard Neal, who requested the GAO Report, “[g]overnment selection tools should offer clear guidance in understandable language to ensure users are able to find the coverage that works best for them. Choosing the wrong plan can have real, negative consequences for beneficiaries, like higher out-of-pocket costs or limited access to providers.”

The Centers for Medicare & Medicaid Services (CMS) plans to introduce a revised version of the MPF prior to the upcoming Annual Coordinated Election Period (ACEP) – the period during which individuals can make coverage elections for the following year between October 15th and December 7th.  The GAO Report notes that a “public preview phase” is scheduled for early August 2019, “with the goal of routing 100 percent of users to the redesigned MPF by mid-August.” CMS notes that “[t]he full launch, scheduled for October 1, 2019, will route all users to the redesigned MPF, and they will no longer use the legacy MPF.” As of the date of this Alert, August 8, 2019, the revamped MPF does not appear to be publicly available.

This roll-out of a new MPF occurs with a backdrop of significant Medicare changes effective in 2020 that will make enrollment decisions even more challenging (e.g., the expansion of supplemental benefits in Medicare Advantage for individuals with chronic conditions and a restriction on the type of Medigap policies that can be sold to individuals who are eligible for Medicare after January 1, 2020).  At the same time, CMS outreach and enrollment materials are no longer a neutral presentation of all Medicare options. As the Center has documented elsewhere, since the Fall of 2017 CMS’ outreach and enrollment materials have encouraged beneficiaries to choose a private Medicare Advantage plan over traditional Medicare, instead of objectively presenting enrollment options.

Significant Findings by GAO

Among other findings, the Report states that the Medicare Plan Finder currently:

  • “Requires navigation through multiple pages before displaying plan details,
  • Lacks prominent instructions to help beneficiaries find information, and
  • Contains complex terms that make it difficult for beneficiaries to understand information.”

In response, CMS noted that it is redesigning the MPF to, among other things, “make it more usable for beneficiaries … improve the navigation of MPF by providing more prominent explanations on how to use [it]; reduc[e] the steps users must take to get a more detailed coverage information … [allow users to] more easily switch between” different topics and “improv[e] the filter and sort functions”.

With respect to the current MPF, the GAO Report notes that cost estimates on the plan results pages are incomplete because they do not adequately account for the option of Medigap coverage. According to the Report, “the redesigned MPF will allow beneficiaries to do estimated cost comparisons of MA to all their original Medicare options, such as original Medicare with a Medigap plan and a prescription drug plan.”

Additionally, there is a lack of information concerning MA plan provider networks. “According to a CMS-sponsored study” notes the Report, “determining if specific providers are in an MA plan provider network is a key factor for beneficiaries when making coverage decisions, and beneficiaries stated in user testing that they must have this information.” MA provider directories, however, will not be part of the new MPF, at least initially. According to GAO, “CMS officials also told us that they are currently examining how to integrate MA plan provider information, but this is not part of the redesigned MPF being released in August 2019. The officials said they are working with the plans to develop requirements to help support the integration of provider directories into future versions of MPF.”

What Role Will Coverage Tools Play?

According to CMS, the MPF will be migrating from a platform primarily used to compare Medicare Advantage and Part D plans to one that will more broadly help compare coverage options, including the choice between traditional Medicare and MA. According to GAO, “CMS plans to provide more information to [sic] the redesigned MPF to help beneficiaries understand their coverage options and decide whether original Medicare or MA is right for them.”

Described in the GAO report as “additional decision support tools for beneficiaries,” the www.medicare.gov website currently includes several tools that are promoted as assisting individuals in making such choices. The Center for Medicare Advocacy and others have expressed concern regarding the accuracy of such tools. As discussed in a November 2018 CMA Alert, the Center and the Medicare Rights Center (MRC) sent a joint letter to CMS expressing concerns with these tools, among other things. The letter stated that the Compare Coverage Options tool “may inappropriately and prematurely encourage individuals to enroll in MA – by making overly-broad suggestions to do so when more nuance is required, and by failing to present individuals with the full array of Medicare coverage options.” For more details about these concerns, see the Center’s Alert of October 5, 2018.

According to the GAO Report, however, it appears that the revised MPF will make even greater use of such tools:

Officials also told us that CMS is incorporating the functionality of the additional decision support tools currently available on the MPF landing page – Help with Your Medicare Choices and Estimate Medicare Costs – into the redesigned MPF to help beneficiaries understand their coverage options and compare their estimated costs across these options. In June 2019, CMS officials stated these additional tools will also continue to appear as separate links on the MPF landing page.

Will CMS Materials Continue to Inappropriately Steer People Toward Medicare Advantage?

As noted in the GAO Report, “[a]s a primary source of information to compare Medicare coverage options, CMS’s goal is for MPF to be a trusted and neutral resource for Medicare beneficiaries, according to agency officials.” The Center is concerned about further reliance on this decision-making tool, which, at best, provides incomplete information. Further, to the extent that MPF offers additional decision-making information, via a tool or any other means, it must remain neutral with respect to describing all coverage options.

Unfortunately, CMS materials since the Fall of 2017 have not maintained such neutrality. Rather than presenting differences between traditional Medicare and private MA plans in an unbiased manner, CMS material has overplayed the pluses of MA and downplayed minuses in a manner that is highly misleading, at best. Advocates have raised concerns about both CMS’ proposed and finalized revisions to the Medicare & You handbook, online comparison tools discussed above, and education and outreach materials. This has included CMS’ enrollment period email campaign last Fall that downplayed or entirely left out the option of traditional Medicare, coupled with yet another email campaign that actively promoted enrollment in MA plans.  As noted in a December 2018 New York Times article by the late Robert Pear, a former chief actuary of CMS “said the emails sounded ‘more like Medicare Advantage plan advertising than objective information from a public agency.’”

At this point in August 2019, it is unclear to what extent this pattern of inappropriate MA steering will continue in the redesigned MPF, the as-yet unreleased 2020 Medicare & You handbook, and the upcoming education and outreach campaign for the Fall enrollment period.  We urge CMS to return to a neutral and unbiased presentation of coverage options for Medicare beneficiaries.

Conclusion

Medicare beneficiaries and those who assist them will have limited time to acclimate to the revised MPF prior to the upcoming Annual Coordinated Election Period. We hope that the revised MPF will provide information in an objective manner, as required by law, and that other CMS materials will follow suit.

August 8, 2019 – D. Lipschutz

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