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The Centers for Medicare & Medicaid Services (CMS) recently suspended a policy known as seamless conversion, a practice that allows select insurers to auto-enroll newly eligible Medicare beneficiaries in an issuer’s commercial or Medicaid managed care product into one of the same company’s Medicare Advantage (MA) plans. In light of recent inquiries, including from the Medicare Rights Center, CMS decided to temporarily halt the acceptance of all new seamless conversion proposals from plans.
Medicare Rights applauds CMS for issuing a moratorium on new seamless conversion arrangements, releasing data on MA plans that currently employ this practice, and for reviewing the existing policy. We believe policies should be advanced that encourage people new to Medicare to make an active and informed choice about the coverage option(s) that are right for them, selecting among Traditional Medicare, Medicare Advantage plans (including integrated Medicare-Medicaid options), supplemental Medigap policies, and stand-alone Part D prescription drug plans. In general, we do not believe that opt-out mechanisms, as allowed through seamless conversion, facilitate this type of active decision-making. Further, it concerns us that people new to Medicare are auto-enrolled in MA plans through a seamless conversion process that does not necessarily give preference to their current health care providers, medications, needed services, and so forth, depending instead only on whether the MA plan is owned and operated by the same parent organization as their previous coverage.
As CMS looks to revise their seamless conversion policies, we are hopeful that the agency will continue to proceed with caution and to allow this practice in only the most limited circumstances. Further, we urge the agency to adopt more robust consumer protections as part of this practice, including requiring write-in confirmation by the beneficiary, enhancing outreach and notification, allowing a Special Enrollment Period for those auto-enrolled, and more. These protections were outlined in a letter to CMS leadership from Medicare Rights and allied organizations.
Making a choice about one’s Medicare coverage when initially eligible is critically important, particularly in states with limited Medigap enrollment rights. In many states, a beneficiary will have limited opportunities to purchase a Medigap policy at a later date if he or she initially opts for or is converted into an MA plan. These considerations must be made clear to people newly eligible for Medicare so that they can make a fully informed choice among their Medicare Advantage and supplemental Medigap options.
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