Health Net and several other administrators of Medicare Advantage plans were issued fines from the Center for Medicare and Medicaid Services (CMS) for errors in their updates to people enrolled in the MA-PD plans. The penalties, issued in October 2013, were for incorrectly stating plan information in annual notices to Medicare beneficiaries enrolled in the Advantage plans and ranged from $23,410 up to $86,530.
Medicare penalties on the fine print
All of the violations occurred in the Evidence of Coverage (EOC) booklets or Annual Notice of Change (ANOC) notices sent to plan members for the 2013 contract year. While these dense documents are seldom read by the actual plan members, they are official documents upon which decisions on the part of the Medicare Advantage plan or member will use to make decisions. It’s nice to know that in their spare time CMS employees comb through sleep provoking documents for errors.
Notice of imposition of Civil Money Penalty
CMS has determined that the failure by your organization to mail accurate ANOC/EOC documents to Medicare enrollees is a deficiency which directly adversely affected or had the substantial likelihood of adversely affecting these enrollees. The MA-PD failed to provide Medicare enrollees with vital information about their benefits and cost-sharing that would have allowed them to make fully informed choices concerning their Medicare health care and prescription drug options during the 2013 Medicare Annual Open Enrollment Period. From CMS notice to Medicare Advantage plan
Enrollment figures into fines
Fines are partially based on how many Medicare Advantage members were affected. Even though the Health Net error was only one line, because 8,600 individuals were potentially misled their fine was larger than other MA plans for similar violations. The fines which are nasty slaps for essentially typographical errors illustrate how serious CMS is about maintaining the integrity of the Medicare Advantage program.
Notice of Imposition of Civil Money Penalty for Medicare Advantage – Prescription Drug Plan Contracts:
Abbreviated list and typographical errors that led to the monetary fines by CMS issued on October 24, 2013. [Medicare Compliance and Audits]
- Centene incorrectly stated that beneficiaries do not have a coverage gap.
- Centene incorrectly stated the limit for the Initial Coverage Stage as $4,750. The correct limit is $2,970.
Health Net Life Insurance Company (H5520)
- Health Net incorrectly listed the maximum out of pocket (MOOP) amount as $2,000. The correct amount is $2,500.
Independence Blue Cross
Keystone Health Plan East, Inc. (H3952)
- Independence incorrectly listed the Part D Prescription Drug deductible for 2013 as $100. The correct amount is $280.
MMM Healthcare, Inc. (H4003)
- InnovaCare incorrectly stated that beneficiaries do not have a coverage gap.
Medical Card System, Inc.
MCS Advantage, Inc. (H4006)
- MCS failed to include the cost sharing amounts for prescription drugs
- MCS failed to include 2013 deductible amount of $147
- MCS failed to include 20% cost sharing for doctor office visits.