Reprinted with AIS Health permission from the December 5, 2019, issue of RADAR on Medicare Advantage

Despite a major overhaul to the Medicare Plan Finder (MPF) that was readied in time for the Annual Election Period ending on Dec. 7, multiple reports at press time indicated that the online tool was providing inaccurate cost estimates for users, especially relating to prescription drugs. In a blog post responding to the reports, CMS said it stands by the accuracy of the tool, but it acknowledged that it has been making updates to the MPF as issues are flagged, giving weight to consumer advocates’ concerns that CMS did not allow enough time for testing the tool before rolling it out.

With the goal of offering a more streamlined and personalized shopping experience at Medicare.gov, the MPF this year underwent a major makeover that reportedly cost $11 million. Sources such as the Consumer Assessment of Health Plans Survey, the “Modernizing Medicare Plan Finder” report from the National Council on Aging and RAND research had raised multiple navigability issues with the tool and prompted CMS to take on the redesign. But after promising consumer advocacy groups that the new version would be available to use alongside the legacy MPF for “much of the summer,” CMS dropped the new plan finder on Aug. 27 — just seven weeks before the Oct. 15 start of the AEP.

“The Medicare Plan Finder is a critical tool for beneficiaries to make plan selections — and even more so this year in which Medicare beneficiaries on average have the choice of 28 different [stand-alone Part D] plans to enroll in,” says Amber Christ, directing attorney with Justice in Aging, referring to a recent Kaiser Family Foundation analysis.

“At the outset, CMS did not provide enough time to test the functionality of the tool, which has led to ‘testing in real time’ with real ramifications to Medicare beneficiaries and their ability to access care,” laments Christ. Shortly after the MPF’s late August unveiling, Justice in Aging joined with the Center for Medicare Advocacy, the Medicare Rights Center and the National Council on Aging to issue a letter to CMS arguing that it did not give counselors enough time to familiarize themselves with the tool, and criticizing the decision not to allow them to fall back on the legacy MPF, which was retired at the end of September.

Meanwhile, a key feature of the tool was missing: the ability to sort Part D plans based on a beneficiary’s total out-of-pocket drug costs for the rest of the year.

CMS explained to AIS Health in September that the feature was always meant to be included in the new plan finder but couldn’t be completed in time for the late August launch. And the agency did indeed add it by the start of the AEP, when it also began enabling consumers to compare expected drug costs in stand-alone Part D plans and MA plans with prescription drug coverage and automatically load their current prescription drug list (if they are existing Medicare beneficiaries and provide their Medicare ID number).

Reports Suggest Emphasis on Premiums

But a recent Health Affairs article observed that the new MPF “explicitly emphasizes the monthly plan premium over arguably more relevant information — estimated total drug costs — which also account for expected out-of-pocket costs.” Meanwhile, total drug costs are “displayed in a small font amidst other information,” and the tool lists available plans starting with the lowest premiums, potentially steering users toward plans with low premiums when previous research has suggested this leads beneficiaries to spend more than necessary on yearly drug expenses, observed the article.

Other news reports offered detailed accounts from users around the country. When using the MPF to compare three drug plans for a client, a Medicare consultant in Wisconsin found that the summary page indicated that one of her client’s medications would not be covered — but upon clicking on “plan details” was informed that all of them would be covered, according to a Nov. 25 article from ProPublica. Further research on the plans’ websites revealed that coverage depended on which version of the same high blood pressure medication the member was taking.

In North Carolina, officials with the state’s Seniors’ Health Insurance Information Program told North Carolina Health News that costs for enrollees who receive low-income subsidies were not accurately reflected in the plan finder, and another not-for-profit agency reported that beneficiaries who entered their new Medicare ID numbers saw their forms automatically repopulate with their Social Security numbers, which were supposed to be removed from the process. And an administrator in Nebraska’s Dept. of Insurance told ProPublica that she’d flagged about 100 errors with the new tool since Oct. 1.

CMS: Information Is ‘Current,’ ‘Accurate’

“Distressed” by “the media coverage talking about ‘glitches’ or ‘malfunctions’” in the MPF, a CMS blog post dated Nov. 27 with no byline said the new tool “displays the most current and accurate information on premiums, deductibles and cost sharing that Medicare Advantage and Prescription Drug Plans provide.” That information, added CMS, “changes frequently because plans regularly update drug formularies and renegotiate drug prices,” which is “good for beneficiaries.”

CMS also reported that traffic on the plan finder website is 14% higher than last year and that the agency is already “seeing high percentages of plan switching, likely because new supplemental benefits are appealing.” However, the agency is not done improving the tool and has incorporated additional changes during the AEP as it receives feedback from users and stakeholders, including beneficiaries, caregivers and State Health Insurance Program counselors who have provided “meaningful suggestions,” added the blog post. “As we’ve said, the Plan Finder redesign is an iterative project, and in the coming months we’ll be scoping out additional improvements that we can implement based on lessons we learn this year.”

“We appreciate that CMS is working diligently to address problems that come up,” says Christ. “Our concern is that many people have already made decisions based on inaccurate plan finder information.”

Advocates Want More Flexible SEP

To ensure that beneficiaries do not experience harm, Justice in Aging has asked CMS to make the Special Enrollment Period (SEP) more flexible and to widely advertise its availability, she adds. The SEP applies when beneficiaries receive inaccurate or misleading information from the government, but it is generally narrow and requires burdensome documentation by beneficiaries, according to Justice in Aging.

That’s not to be confused with the three-month Open Enrollment Period, which starts in January and allows individuals who made an MA plan choice to switch. While that period may “help a subset of individuals who early on realize their plan selection is harmful…many won’t encounter a problem until later in the year, and they too need a way to fix a mistake that was based on erroneous or misleading plan finder information,” suggests Christ. Furthermore, the three-month open enrollment period only applies to MA, and not to PDP enrollment, she points out.

Even with MPF glitches, the AEP appears to be robust, with overall year-to-date enrollment up 7.2%, according to Credit Suisse. “The big ‘wait and see’ question will be if and when enrollees depending on Plan Finder realize they received incorrect information,” says Lindsay Resnick, executive vice president at Wunderman Thompson Health, in an email to AIS Health. “Given that the vast majority of beneficiaries complete their purchase through a licensed Medicare Advantage agent or directly with the health plan, we may not see major issues. That said, for the integrity of the MA program, the onus is on CMS to get in front of this issue with consumer facing communications about Plan Finder issues as well as clear and simple explanations of OEP rules.”

Meanwhile, private shopping platform Connecture — which prides itself on using pharmacy-specific drug pricing data (not just regional averages) collected from the largest number of carriers in the country — says it has seen significant growth in enrollments this AEP through all channels (broker, call center and direct-to-consumer) via its PlanCompare solution.

Connecture: Calculating Drug Costs Is Key

“This AEP, especially, has afforded Connecture the opportunity to educate on the importance of collecting (and saving) drug lists, knowing accurate drug costs and understanding why $0 premium plans can end up costing more if consumers don’t understand their total annual out-of-pocket estimates,” says Bill Keyes, senior vice president of sales and marketing with Connecture. “Our total cost calculators take multiple Medicare plan factors into consideration (such as the donut hole) all of which ultimately drive consumers to finding their best fit plans.”

View the Health Affairs article at https://bit.ly/2R8WK7L and the CMS blog post at https://go.cms.gov/2qYbEmJ.

Contact Christ via Vanessa Barrington vbarrington@justiceinaging.org, Keyes via Connecture Marketing Director Kara Tarantino at ktarantino@connecture.com or Resnick at lindsay.resnick@wunderman.com.

By Lauren Flynn Kelly