The Med Diva

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Countdown to Medicare Part D Open Enrollment

Open Enrollment for 2012 begins on Saturday, October 15, and ends on Wednesday, December 7, 2011.

 Day 18: An open letter to Donald Berwick about Open Enrollment

 As if Medicare Part D plans weren’t confusing enough, now the government has gone ahead and changed the dates for the Annual Coordinated Election Period (also known as Open Enrollment) for the 2012 plan year.

Under a provision of the Patient Protection and Affordable Care Act, the Medicare annual Open Enrollment Period is now October 15 through December 7. (For the past 6 years, it was held November 15 through December 31.)

According to the Centers for Medicare & Medicaid Services (CMS), the new dates give people a full seven weeks to compare prescription drug plans and make decisions. The change also ensures that you’ll have essential plan materials and membership cards in hand and ready to use on January 1, 2012, when your new coverage starts.

However, as someone who has climbed mountains of government red tape to help beneficiaries understand their prescription drug benefit, let me share my observations and thoughts, which I have summarized in this open letter to Donald Berwick, CMS Administrator:  

An Open Letter to Donald Berwick, CMS Administrator

Donald Berwick, MD, MPH
Centers for Medicare & Medicaid Services (CMS)
Department of Health and Human Services
Room 445–G, Hubert H. Humphrey Building, 200
Independence Avenue, SW.,
Washington, DC 20201

Dear Mr. Berwick:

For the past 6 years, the Annual Coordinated Election Period for Part D prescription drug plans has been November 15 to December 31. This set time period made sense, because it was easy for beneficiaries to remember that they had until the very end of the year to enroll in a new plan. Over the years, these dates have become ingrained in people’s minds, just like remembering to check the smoke detectors twice a year when setting the clocks forward or back.

So why, after 6 years, did our government change the dates? I called your press office last week to find out, but I was curtly dismissed by an employee who told me to go to the Medicare website for information, and that he’d call me back in a few minutes. I’m still waiting for him to call back…

Yes, the new Open Enrollment dates give beneficiaries more time (a whopping 7 more days) to compare from the approximately 30 different Medicare Part D plans offered in each region. But was it really necessary to confuse millions of people for the sake of one extra week? Honestly, if Medicare Part D weren’t so complicated in the first place, no one would need this extra 7 days to compare plans. Furthermore, if CMS didn’t make Part D sponsors jump through so many regulatory hoops—especially at the very last minute—plans wouldn’t have any trouble getting essential plan materials and membership cards to members on time.

And who was the wise guy who decided that December 7 was a good date for the Open Enrollment period to close? Why not December 3 or December 19 for that matter? What was the rationale for choosing such a random number? I’m sure that CMS employees and Med D enrollment representatives will be happy to have extra time off to spend with family during the holiday season, but December 7 is not an easy date to associate with the close of Open Enrollment. In fact, the only reason people should remember December 7 is as the day Pearl Harbor was bombed. 

Mr. Berwick, you and I both know that many beneficiaries are going to forget these dates and miss the new deadline for making plan changes. According to the Center for Medicare Advocacy, Inc., CMS is conducting outreach about the earlier deadline and will monitor the situation; however, there are no plans to allow a Special Enrollment Period (SEP) for those who miss the December 7 deadline.  I can already hear all the telephones, which will be ringing off the hook at Medicare from December 8 on…


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