REVISED – JULY 18, 2000
2001
Standardized Summary of Benefits (SB): Instructions
Deleted text is noted by strikeouts, while new text is noted by redlining.
NOTE: Requirements for use of the standardized SB apply to all Medicare+Choice organizations (M+COs), 1876 cost contractors, and certain managed care demonstration projects, including Medicare Choices, EverCare, DoD Subvention and SHMOs. The general instructions provided below apply to all of these entities. HCFA has developed additional instructions for cost contractors, which are posted on the HCFA web site at: www.hcfa.gov/medicare/2001_qa.htm. A series of Questions and Answers is also provided at this site. M+COs, cost contractors, and the demonstration projects mentioned above are strongly encouraged to review these Questions and Answers and to post any additional questions through the Internet to: summaryofbenefits@hcfa.gov. Since HCFA will post answers to these questions on the web site at regular intervals, M+COs, cost contractors and the demonstration projects mentioned above are strongly encouraged to review the web site regularly for updates.
M+COs and contracting health plans should also review the package of materials that describes contract refinements for CY 2001, which is also available on the HCFA web site. These materials include Operational Policy Letter 2000.121, which provides specific instructions for renewing plans, as well as the revised National Marketing Guide.
For purposes of simplicity, the term M+CO contractor or organization is used throughout the document. The term "plan" now refers to the benefit package offered by an M+CO contractor. Please be aware of this change when reading this document. M+COs and contracting health plans should also review the separate package of materials for renewing plans, which is also available at the HCFA web site.
BACKGROUND
The SB document is the primary pre-enrollment document used by M+COs to inform potential members of the plan benefit packages offered by M+COs. Similarly, Medicare beneficiaries have indicated the SB is the single most important document produced by the M+COs that assists the beneficiary in making a health care selection.
M+COs participating in the M+C program often provide a side-by-side comparison of plan benefits to the original Medicare fee-for-service benefit package so the potential member can visualize the benefit enhancements the M+CO offers beyond the original Medicare program. In the past, M+COs’ SBs ranged from a simple benefit comparison matrix to sophisticated documents resembling member handbooks with a foldout benefit comparison matrix. In addition, each M+CO was allowed to use its own structure, format, and descriptive language in providing benefit information to prospective Medicare beneficiary members. Such a wide variety of documents caused confusion and difficulty regarding beneficiary comparison shopping for the plan best suited to meet the individual beneficiary’s health care needs. For these reasons and others, the Health Care Financing Administration (HCFA) required M+COs participating in the M+C program to use a standardized SB beginning with the annual election period for Contract Year (CY) 2000.
The standardized SB is a stand-alone marketing document that is based on a report generated from the Plan Benefit Package (PBP) describing plans’ benefits and costs. The SB contains three sections: (1) the beneficiary information section, designed to inform potential members of important aspects of participating in the M+C program (two pages, standard format, and text); (2) the benefit comparison matrix section (approximately 10 pages, standard format and text); and (3) the M+CO special features section (4 pages of promotional text and graphics; free format and text.) The SB is a "summary" document and therefore not intended to include benefit information to the same degree as the Evidence of Coverage. The SB and Medicare Health Plan Compare will contain the same information in the same format for CY 2001.
In the past, HCFA reviewed SBs to ensure that the information provided matched the information provided in the Benefit Information File (BIF), which was submitted with each plan’s Adjusted Community Rate (ACR) Proposal. For CY 2001, the new PBP will replace the BIF and include much more information about each M+CO’s benefit packages. In addition, Sections 1 and 2 of the 2001 SB have been integrated into the PBP and will be generated as output reports from the PBP. These sections will be generated in similar format and with similar language as required in the standardized SB for CY 2000, but will also include some changes based on comments from the managed care industry, Medicare beneficiaries, and other interested parties. M+COs should generate Sections 1 and 2 from their completed PBP, download these sections into the appropriate publishing software, and combine them with Section 3 to form a complete SB. M+COs may make only the necessary modifications permitted by HCFA (described below) and must then submit the SB to HCFA for review.
HCFA POLICY DIRECTIVES
1. Federal Pre-Emption of State Regulatory Requirements:
In order to avoid the possibility of conflicting State and Federal regulatory requirements regarding utilization of the standardized SB, HCFA will use its Federal pre-emption authority. HCFA interprets the M+C regulations to require a standardized format and language for description of benefits; this standardization must be used in order to comply with Federal law. Under longstanding constitutional principles of Federal pre-emption, restated in section 1856(b)(3)(A), with respect to M+C standards specifically, any state law that is inconsistent with Federal requirements is pre-empted.
2. Applicability of the Standardized SB to Employer Groups:
Enrollees whose source of enrollment is through an employer-sponsored group are not currently included in the mandated use of the standardized SB for either annual notification or initial marketing purposes.
3. Value-Added Items and Services:
HCFA’s policy regarding Value-Added Items and Services is described in detail in the revised National Marketing Guide (dated June 8, 2000) which is also available on HCFA’s web site as part of the instructions to renewing plans for CY 2001. Briefly, HCFA’s policy with respect to marketing VAIS is as follows. M+COs can market, either through oral presentations or written materials, Value-Added Items and Services (VAIS), but cannot attach any of these materials to HCFA approved marketing materials; this includes the Summary of Benefits, Evidence of Coverage, and any other materials distributed to beneficiaries. However, materials describing VAIS can be included in the same envelope (or, if the materials are distributed in person, within the same set of materials) with HCFA approved marketing materials.
M+COs that choose to offer VAIS must adhere to the requirements outlined in Chapter 5, Section 4 of the revised National Marketing Guide, including the use of specific disclaimers. However, since VAIS are not benefits as defined in the Guide and HCFA regulations, HCFA will not require prior approval of materials describing VAIS. HCFA will only review these materials on monitoring visits to ensure compliance with these requirements. HCFA may initiate a monitoring visit if it becomes aware that the M+CO has distributed materials describing VAIS without the appropriate disclaimers or in violation of the requirements stated in the Guide. HCFA will also investigate complaints by beneficiaries regarding VAIS, just as it would other possible violations of HCFA requirements.
TECHNICAL DIRECTIVES
M+COs should first carefully review the separate instructions for completing the PBP and related Questions and Answers (also available at http://www.hcfa.gov/medicare/2001_qa.htm) and complete their PBP before producing Sections 1 and 2 of the standardized SB. M+COs should print a copy of Sections 1 and 2 before submitting their PBP and carefully review these sections before submitting their PBP by July 3rd. HCFA reviewers will have the ability to generate Sections 1 and 2 from the M+CO’s PBP and will compare these sections to those submitted as part of the M+CO’s entire SB. Any discrepancies between the sections submitted by the M+CO and those produced by HCFA that are not described below must be corrected before the SB will be approved by HCFA.
GENERAL INSTRUCTIONS
Section 1 – Beneficiary Information Section
Section 2 – Benefit Comparison Matrix
NOTE: The SB comparison matrix will be generated by the PBP in a chart format with the required language. Therefore, the information included in the PBP must first be correct in order for the SB comparison matrix to also be correct. M+COs should review the comparison matrix to ensure that all of the information presented is correct. Information presented in the comparison matrix must match the information presented in the PBP, with the exception of the permitted and/or necessary changes discussed below. If any changes are required, the M+CO must make these changes in the PBP prior to the July 3rd deadline for submission of ACR/PBP, generate a revised SB benefit matrix, and include this matrix in its SB. HCFA reviewers will have with the benefit comparison matrix that is generated by the PBP and will compare this with the matrix provided as part of the plan’s SB. Any discrepancies between the matrix generated by HCFA and that provided by the plan (with the exception of those permitted below) will result in disapproval of the SB.
PERMITTED CHANGES TO SB LANGUAGE AND FORMAT
Remember: M+COs are only permitted to make changes to the benefit matrix as described below; any other changes will not be permitted. M+COs cannot add benefits to the comparison matrix generated by the PBP. M+COs cannot add bullets or other information to the comparison matrix or alter existing information. M+COs cannot change or delete information from the comparison matrix. M+COs should first download their SB report from the PBP to a software program and then make the necessary changes in this new document.
If the M+CO offers benefits that are not fully described in the comparison matrix, the M+CO may include this information in Section 3, discussed below. The M+CO may not change or amend the language in the comparison matrix unless as provided below.
This footnote must be referenced after every statement in the Original Medicare (OM) column that describes the required Medicare coinsurance, i.e., "You pay 20% of Medicare approved amounts." This footnote must also appear at the bottom of each page that contains this statement. This statement is contained in the OM column describing the following benefits:
This footnote must be referenced after every statement in the OM column that describes the following benefits and after footnote (1), where applicable. The text of this footnote must appear at the bottom of each page that contains this statement. This statement is contained in the OM column describing the following benefits:
This footnote must be referenced after the words "benefit period" in the OM column describing Inpatient Hospital Care and Skilled Nursing Facility and the text of this footnote must appear at the bottom of the page on which these benefits are described.
This footnote must be referenced after the statement, "Days 91-150: $338 each lifetime reserve days" in the OM column describing Inpatient Hospital Care. The text of this footnote must appear at the bottom of the page on which these benefits are described.
"You do not pay this amount if you are admitted to the hospital within [insert number of days or hours, whichever is applicable] for the same condition."
This sentence should follow the first sentence that appears: "You pay [amount] for each Medicare-covered emergency room visit." No additional changes to this language are permitted.
"Your out-of-pocket costs may be limited."
The M+CO may then describe any limits on the member’s out-of-pocket costs in Section 3 and provide the appropriate cross reference in the matrix by inserting the sentence, "Please see page __ for more information."
"You may receive care from any Medicare-certified hospice." This plan does not cover hospice services.";
M+CO that offer hospice care may
"See page ___ for information about this benefit."
"Contact [plan] to determine if the above applies to your prescription drug benefit."
This will appear even if the M+CO indicates in the PBP that there is no
drug benefit beyond Original Medicare. This statement is
incorrect, since the Diabetes Monitoring category does not include
prescription drugs. Therefore, M+COs can must remove this sentence delete the entire
sentence from their SB if this is not applicable, but should
be sure to indicate in their PBP that there is no drug benefit beyond Original
Medicare.
"Additional benefits available. Ask [name of plan] for details."
M+COs must delete these sentences in the plan column of the SB matrix if they are not applicable.
"Plans can calculate the part you pay in different ways. Please ask [name of plan] about how we determine drug costs that count towards these limits."
M+COs must delete this sentence if they do not offer prescription drug coverage, or if they offer drugs but do not impose dollar limits on prescription drugs.
With respect to the Acupuncture and Health/Wellness Education categories, the M+CO must insert the sentence, "You pay 100%" if the M+CO does not offer these services as additional or mandatory supplemental benefits. The Original Medicare column currently includes this language for these categories.
Note: If the M+CO offers any of these benefits as optional supplemental benefits and describes these benefits in Section 3 of their SB, then the M+CO must also insert the sentence, "See page ___ for more information about this benefit" in the plan column of Section 2 for each benefit offered. This sentence would include the appropriate page reference in Section 3 where the description of this benefit could be found.
"You may use any provider."
To more fully describe the plan’s rules regarding the use of providers for these benefits, M+COs may add the following sentence: "See page __ for additional information about this benefit."
Calendar year benefit limited by prior partial or complete use of 190-day lifetime treatment in a psychiatric hospital. (If your benefit does NOT have such a limitation, then the Minimum number of benefit days in the calendar year must be 190 days.)
If this sentence does not appear in the SB as generated from the PBP, then the M+CO must manually insert this language in their SB.
Section 3 -- Plan Specific Special Features
This section is limited to a maximum of four (4) pages of promotional text and graphics and is not standardized with regard to format or content. Section 3 is used by the M+CO to describe special features of the M+CO beyond information contained in Sections 1 and 2 of the SB. Section 3 may contain non-standardized language, graphics, pictures, maps, etc.
The 4-page limit means that the information is limited to 4 single-sided pages or 2 double-sided pages. There are no exceptions to this limitation.
If an M+CO elects to display optional supplemental benefits in the SB, they must appear in Section 3. The M+CO must include a brief description and any associated premium/co-pay information for these benefits if the M+CO elects to include them in the SB.
M+COs may use this section for mandatory supplemental benefits that do not appear in the comparison matrix section. If the M+CO chooses to further describe a benefit in this section that appears in the comparison matrix, the M+CO may add a note at the bottom of the box to refer to this section. If the M+CO chooses to do this, the note must say "See page ___ for more information on (Enter the benefit category exactly as it appears in the left column.)." For example, if an M+CO wishes to further describe their dental benefit, in the Health Plan column of the SB, in the row titled Dental Services, they would add a note at the bottom saying "See page ____ for more information about dental services." Use of language regarding superlatives, testimonials, and other marketing statements is governed by the marketing rules found in the Medicare Managed Care National Marketing Guidelines.
Closing Note:
This standardized SB is designed to provide the M+CO plan with adequate descriptive information to perform marketing of the M+CO’s plans while at the same time assisting potential Medicare beneficiaries in performing comparison shopping for the health care provider best suited to meet their needs. The standardized SB will also be used to inform existing M+CO members of the benefit changes for the new contract year. Should you require assistance in clarification or use of this document, please contact your HCFA Regional Office Plan Manager. You may also post your questions through the Internet by writing to: summaryofbenefits@hcfa.gov. The "SB Questions and Answers," will be updated regularly and posted on the Internet at: http://www.hcfa.gov/medicare/2001_qa.htm.
Return to CY 2001 ACR/PBP Information
Last Updated July 20, 2000
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