Digital content delivery is the future of Medicare member communications – and the future is now. But what, exactly, does “going digital” entail?
Let’s look at two of the key pieces to implementing and executing an effective digital content delivery program – compliance and platform.
Compliance: Get it Right or Pay the Price
Maintaining compliance in Medicare communications can be confusing, difficult and frustrating. Regulatory code arrives in large, fast-moving waves. Segments of regulations conflict with each other. Interpretation and implementation are challenging and resource-intensive. If plans don’t get this right, compliance can be extremely costly. CMS assessed more than $9 million in Civil Monetary Penalties (CMPs) in 2015. The average fine was $761,000 – that’s a 225% increase from the previous year.
The vast amount of regulations buried inside of the CMS Medicare Marketing Guidelines have a huge impact on plans – and these challenges don’t look to abate anytime soon. CMS anticipates extending its use of CMPs into additional areas of non-compliance in the future. Needless to say, health plans must do their homework and stay vigilant when implementing digital member communications.
When planning your digital strategy, there are three main sources of regulation and compliance to consider:
Health Insurance Portability and Accountability Act (HIPAA)
The HIPAA privacy rule requires protection of all member health information. In essence, this means plans must implement security measures that will prevent exposure of this information in the digital arena. The internet is a very dangerous place for private information if appropriate precautions are not taken. Additionally, plans are required to maintain a 10-year archive of all Medicare member communication, which also must remain secure.
CMS Medicare Marketing Guidelines
At 125 pages, CMS Medicare Marketing Guidelines pack a solid punch. These rules are a major driving force for plan policy when it comes to communications. The regulations unlock the door for digital content delivery, providing plans with the ability to use digital delivery methods: “Plans/Part D Sponsors may provide materials using different media types (e.g., electronic or portable media like email, CD, or DVD).”
Section 508 of the Rehabilitation Act
The CMS Medicare Marketing Guidelines specifically mentions this section of the law – which requires all documents to be “accessible” for those with disabilities. For instance, providing documents in large print or in Braille. For digital communications, this includes both delivered content and websites.
Digital Platforms: The Launchpad for Communications
At ABG Communications, we’ve spent a lot of time studying, testing and creating content delivery platforms. Our research and market best practice tell us that a comprehensive platform with quality U/X, strong security, data/document management capabilities and content management functions are essential for successful digital member communications.
Expanding the discussion to a holistic level, we see that the following five components are the pillars of a great member communication practice:
Content Transport Mechanism
In the mobile world, email and text are the most effective mediums to communicate. Sending URL links that direct members back to the member-facing portal to view content (and authenticate identity) provide member communications in the format consumers want, and with tremendous ROI rewards for plans.
Member-Facing Portal (Website)
A member-facing portal/website is the anchor for a health plan’s communication system. All dynamic communications can – and should – take place here. Besides optimizing member security, this model brings the member into the plan website environment, providing opportunities to deepen the engagement level through cross-links into and across the site architecture.
Opt-in and Preference Management Function
This function systematically captures member communication preferences, including the preferred channel by which they would like to receive the information (mail, text, email), language preferences and requests for alternate formats, like large-print and Braille.
Content Generation Functions
The content generation process has a lot of moving parts – too many to describe in a blog post. The most basic, and critical of these is the Adobe® Portable Document Format (PDF) files for content fulfillment. Ubiquitous (and free) availability, operating system agnosticism, accessibility and security combine to make PDFs the go-to for content delivery.
A process that actively manages the outcomes of events that didn’t end with conclusive evidence of member receipt within required time intervals should be a part of any good platform. Capturing records of both “hard” and “soft” bounces to track email open events should trigger a resulting action to maintain compliance and service levels. ABG’s system uses a “switch to paper” process that activates a printed/mailed fulfillment in the event of these outcomes.
Ready for the Future?
Digital content delivery is the present and future of Medicare member communications. If you’re ready to get your plan up to speed, contact ABG Communications to learn more.