Medicare Rights Urges Beneficiary-Centered Medicare Enrollment Reforms

The Centers for Medicare & Medicaid Services (CMS) recently released a Request for Information (RFI) on “AI Tools for Medicare Experience Modernization.” In the RFI, CMS explains the agency is seeking “information regarding artificial intelligence (AI) and machine learning (ML) platforms and services that are capable of enhancing the Medicare experience for beneficiaries across digital and voice channels.”

The request is focused on using this technology in various Medicare enrollment functions, noting that “CMS is interested in solutions that can provide personalized plan recommendations, conversational AI support, predictive analytics, accessible decision support tools, and call center automation to help Medicare beneficiaries make informed plan choices and maximize their coverage.”

As outlined below, beyond responding to CMS, the RFI presents an opportunity to discuss needed improvements and recent incremental changes toward Medicare Rights’ goals of making Medicare enrollment easier to navigate and understand.

All Enrollment Tools Need Careful Vetting

While Medicare Rights agrees that CMS’s existing Medicare enrollment tools should be modernized to improve the beneficiary experience, in our response to the RFI we urge caution with swift AI uptake in this space.

We urge caution with swift AI uptake in the Medicare enrollment space.

Although AI has potential in some areas, it is not infallible, well understood, or always safe. As its current deployment in Medicare through the WISeR model demonstrates, AI is not yet ready to be used in high stakes situations, in an unmonitored way, or where its results cannot be fact checked, reliably duplicated, or clearly explained. Inadequate federal and state AI regulation, as well as the lack of public trust in its accuracy, privacy, safety, and security, likewise indicate it is premature and inappropriate to give AI programs and vendors access to millions of Medicare beneficiaries and their personal information.

Needs of People With Medicare Must be Top of Mind

As CMS considers technology-driven reforms in the future, we urge the agency to center the needs, preferences, and voices of Medicare beneficiaries. Efforts must involve people with Medicare of all ages as stakeholders and ensure that any future policies have strong consumer protections. This includes guardrails that maintain access to assistance pathways that beneficiaries value and prefer, such as the live, in-person, one-on-one help available through State Health Insurance Assistance Programs (SHIPs) and 1-800-Medicare.

Person-Centered Enrollment Help Is Needed

In addition to emerging technology solutions contemplated by the RFI, there are several ways policymakers could act now to address enrollment challenges. At Medicare Rights, we frequently hear from beneficiaries who need help understanding their Medicare coverage options and making enrollment decisions. Whether they choose Original Medicare (OM) or Medicare Advantage (MA), or are shopping for Part D drug coverage, many find the plan landscapes to be cluttered, complex, and confusing. And the stakes are high; there’s often no quick fix if a beneficiary chooses a plan that doesn’t meet their needs.

The following changes to (1) Make Enrollment Decisions Easier and Less Risky, (2) Modernize Notification and Outreach, and (3) Improve Decision-Making Tools, Information, and Resources would help ensure all people with Medicare have access to the information, coverage, and care they need.

Make Enrollment Decisions Easier and Less Risky

The current plan choice environment is overwhelming for beneficiaries and their assisters, who often lack the time or resources for a detailed analysis. Evaluating dozens of plan designs may be particularly burdensome for consumers with limited English proficiency, those with significant health needs, and people with inadequate internet access. Despite the severe consequences of making a poor plan choice—high costs, restricted provider access, and delayed care—there are few remedies. If an enrollee makes a mistake, they may be stuck in a plan that does not meet their needs for up to a year, or locked into MA indefinitely because of the high cost of Medigap coverage.

Standardization, with only high-quality options, would remove some of this complexity and risk.

Standardization, with only high-quality options, would remove some of this complexity and risk. There is precedent for such an approach: Medigap plans are standardized to facilitate comparison. We also support strengthening remedies for mistaken enrollment delays, including by easing beneficiary access to equitable relief and qualifying Part B Special Enrollment Periods (SEPs).

Modernize Notification and Outreach

While most older adults and people with disabilities are automatically enrolled in Medicare Part B, a growing number are not. These individuals must make an active enrollment choice, taking into consideration specific timelines, complex Medicare rules, and their existing coverage. Far too many people make mistakes when trying to navigate this confusing system. The consequences of such missteps can be severe and include steep financial penalties, higher-than-expected medical costs, and lapses in health coverage.

Advance notice from the federal government to people approaching Medicare eligibility about important rules and deadlines would help, but today no such requirement exists.

Advance notice from the federal government to people approaching Medicare eligibility about important rules and deadlines would help, but today no such requirement exists. We recommend that policymakers correct this, as outlined in the BENES 2.0 Act.

Similarly, we recommend enhancing outreach to low-income enrollees by making the Medicare Improvements for Patients and Providers Act’s (MIPPA) engagement work permanent. This program connects low-income older adults and people with disabilities seniors with the financial assistance they need to afford Medicare—the Medicare Part D Extra Help/Low-Income Subsidy and the Medicare Savings Programs.

We also support reducing or eliminating the Part B Late Enrollment Penalty.

We also support reducing or eliminating the Part B Late Enrollment Penalty (LEP). Designed to encourage enrollment when first eligible, it is also imposed on those who simply make a mistake. For as long as they have Medicare, these individuals must pay their regular monthly Part B premium plus an additional 10 percent for each year they delayed signing up. Updates to this structure and approach are long overdue.

Improve Decision-Making Tools, Information, and Resources

Beneficiaries need accurate and easily understood information and, often, individualized assistance. Although Medicare Plan Finder has details about specific plans, it is limited in terms of cost comparisons and supplemental benefits and can be confusing to use, due to the number of plan choices and the complexity of MA and Part D structures. In addition, extant provider directories are wholly inadequate and riddled with errors. Trusted assistance is available through the SHIP program, but it is woefully underfunded.

Medicare Plan Finder modernizations would go a long way to empower beneficiaries. Primary upgrades could include more realistic and predictive estimated costs, as well as more information about supplemental benefits, like coverage and eligibility limits.

Beginning in 2028, MA plans must verify the accuracy of their provider directories every 90 days.

Current regulations have improved access to network information. In the coming years, recent legislative changes will begin to tackle the longstanding problem of inaccurate MA provider directories: Beginning in 2028, MA plans must verify the accuracy of their provider directories every 90 days; the following year, plans will be required to post accuracy scores and protect enrollees from higher cost sharing that stems from incorrect directory information. We urge CMS to implement these reforms in a meaningful and timely way.

We also urge significant and sustained investment in SHIPs. For many beneficiaries, SHIP counselors are their sole source of objective, highly trained, one-on-one Medicare counseling. Despite growing demand fueled by surging Medicare enrollment and an increasingly complex coverage landscape, funding for the program has not kept pace. We recommend sustainable, robust investments, now and in the future.

Read the RFI and our response.