Also see:    Anthem, Blue Cross Blue Shield Affiliates, Humana Head List of Most Member Favorable Part D Values
                         for Commonly Prescribed Maintenance Drugs 
Among Selected $0 Premium 2023 Medicare Advantage Plans-
      Also see:    HealthMetrix Research Identifies Best Part D Values for Commonly Prescribed Maintenance Drugs  
                         Among Selected $0 Premium 2023 Medicare Advantage Plans-11/1/2022

     Also see:  Why Medicare Advantage Plans Should Super-Size Baseline Prevention Screenings-4/1/2022
Also see:  Addressing Inflation Essential for Successful OEP, Age-in, Member Retention, AEP Messaging Strategies-                          2/27/2022 
CMS Messaging & the Medicare Plan Finder Need Upgrades
that Beneficiaries Deserve for Making Informed Choices
 December 1, 2022 

As the 2023 Annual Election Period (AEP) nears the December 7 finish line, I can share personal observations from my perspective as an informed Medicare beneficiary, Medicare Advantage member and health care benefits researcher concerning:

1) The accuracy and choice of CMS messaging targeting Medicare beneficiaries; and 
2) The decline in Medicare Plan Finder (MPF) content available for comparing Medicare Advantage and Part D options.  

Below is the recent CMS email push reminding me to compare my Medicare coverage options -- Medicare Advantage, Part D, Medigap -- during Medicare Open Enrollment (a/k/a AEP).   


Such a deadline reminder is appropriate, however, after recent CMS actions to curb celebrity Medicare marketing pitches, it seems ironic that the CMS messaging (my highlight added) encourages beneficiaries to shop for lower plan premiums in order to save costs.  How different is this messaging from the celebrity marketing pitches urging beneficiaries to find out about all the benefits you deserve or about adding dollars to your monthly Social Security check?  At the very least, shouldn't CMS add a disclaimer advising that lower premium plans do not necessarily save money?

The continued decline in the Medicare Plan Finder (MPF) content available for beneficiaries to make informed decisions about choosing Medicare Advantage and Part D plans is a disappointing trend.  There has been a steady decline in both MPF transparency and relevance over recent years as it has become less ‘forward-looking’ (e.g. dropping estimated annual health care out-of-pocket costs based on health status) while emphasizing ‘rear-view’ past performance (e.g., Star ratings based on data as much as two years old).  

CMS data and content that should be "unlocked" for viewing by MPF users would answer such questions as:

  • What are the current enrollment numbers by plan sponsors for their HMO, PPO and Part D plans in each county?
  • Which MAPD plans offer a Part B premium buy-down?  How much is each monthly premium buy-down?
  • What amounts do MAPD plans offer with Over-the-Counter benefits?  Do unused monthly/quarterly benefits roll-over?
  • How can someone compare which MAPD and Part D plans have the highest or lowest voluntary disenrollment numbers?


[The following is 1/3/2022 HealthMetrix Research correspondence to Chiquita Brooks-LaSure, CMS Administrator, Department of Health and Human Services]

With the Medicare Plan Finder (MPF) entering its 25th year as the online resource portal for Medicare beneficiaries seeking to make Medicare Advantage (Part C) and drug (Part D) informed enrollment decisions, it is apparent that beneficiaries deserve more instead of less transparency surrounding Medicare Advantage and Part D options.  I have witnessed a steady decline in both MPF transparency and relevance over recent years as it has become less ‘forward-looking’ (e.g. eliminating estimated annual health care out-of-pocket costs – OOPC - based on health status) while emphasizing ‘rear-view’ past performance (e.g., Star ratings based on data as much as two years old).  Additionally, while CMS has rolled-out periodic MPF improvements, the site still lacks user-friendly features coupled with challenging navigation issues that average tech-savvy beneficiaries are not accustomed to experiencing on social networking, shopping, medical information, personal banking or travel websites. 

I was fortunate to advise past HCFA/CMS administrator Tom Scully and his senior staff in 2001 about enhancements to the MPF predecessor – Medicare Options Compare (MOC) – including estimated annual out-of-pocket cost (OOPC) comparisons for Part A & B health services by health status.  Cost comparisons were first featured on MOC in 2002 in a rather limited format for beneficiary decision-support.  Unlike the annual CostShare Report OOPC comparisons featured on since 1998, the MOC estimated OOPC comparisons lacked transparency.  Estimated annual OOPCs were derived from Medicare annual expenditure and service utilization reports, typically two years old or older, and then applied to individual Medicare plan premiums, copays, deductibles.  The introduction of Part D drug benefits in 2006 resulted in another layer of estimated OOPCs appearing on MOC based solely on individual beneficiary personal drugs provided.  Estimated health care OOPCs were originally displayed for 5 health status categories (excellent, very good, good, fair, poor) until 2013 when they were limited to 3 health status categories (excellent, fair, poor).  The 2020 MPF simply displayed a single estimated annual OOPC suggested for someone in ‘good health’.  The 2022 MPF has eliminated all estimated annual health services OOPCs leaving only the maximum paid for health services OOPC displayed (e.g. $3,900) as depicted below.


As one of the heaviest MOC/MPF individual users for 24 years relying on the data for producing the HealthMetrix Research annual CostShare Report OOPC comparisons, I have considerable end-user knowledge and observations about what beneficiaries (including myself at age 72) appreciate most for making informed decisions.  A comprehensive, rigorous website assessment into enhancing transparency and adopting user-friendly features should be the keystones for undertaking a “2023 Medicare Plan Finder Initiative -- Build, Back, Smarter.”  Whether CMS embraces MPF enhanced transparency and adopting user-friendly features is dependent on the extent to which CMS will ‘unlock’ existing data for beneficiary consumption.  The following recommendations demonstrate how to configure existing CMS data to aid beneficiaries by expanding the critical knowledge needed for making informed decisions. 

  • Display ‘forward-looking’ estimated OOPC comparisons for combined Health Services and Part D drugs across multiple health status profiles in order for beneficiaries to ascertain which MA+Part D plans will be more/less favorable, especially as declining health status and chronic conditions increase OOPC exposure.  See below how to display such comparisons as found on the HealthMetrix Research Inc. website for over 100 markets in 47 states.   

  • Create a transparent, variable basket of ‘core benefits’ (e.g., primary care/specialist office visits, urgent care, ER visits, hospitalizations) with annual utilization assumptions for 3 health status categories (e.g., excellent, fair, poor).  See below how to display such health status categories and core benefit utilization assumptions as found on the HealthMetrix Research Inc. website.


  • Create a fixed basket of ‘Commonly Prescribed Maintenance Drugs’ from which to forecast and identify which selected MA+Part D plans offer the most/least favorable (or equitable) Part D benefit structure (e.g., formulary choices, tier categories, deductibles, copays, ‘donut hole’ threshold) across multiple health status categories (e.g., excellent, fair, poor).  See below the Part D maintenance drug assumptions that HealthMetrix Research Inc. used to forecast Part D OOPCs for 2022 CostShare Report comparisons in over 100 markets in 47 states.


  • Boost transparency by unlocking and displaying existing MA+Part D Star performance measures and contract membership vital statistics including, but not limited to addressing: 
  1.   Individual county enrollment counts by MA+Part D plan/product as of September 1;
  2.   Annual voluntary member disenrollment counts (ex-deaths, moves out-of-area) as reported to CMS and as a % of total enrollees;
  3.   Annual voluntary disenrollment counts by stated reason and highest frequency (e.g., #1 Problems with coverage of doctors/hospitals, #2 Dissatisfaction with call center hold time);
  4.   Annual member grievances filed per 1,000 members as reported to CMS.
  • Create additional filter selection options for users to view and compare MA+Part D choices across the proposed new features.  The overwhelming number of Medicare Advantage and Part D only options available is daunting to most beneficiaries without having the capability to scale down to 4-5 options for closer comparison and selection.


HealthMetrix Research Inc.

Alan Mittermaier, President
Box 30041
Columbus, OH 43230

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