Annual Notice of Change (ANOC) and Evidence of Coverage (EOC)

2019 Annual Notice of Change and Evidence of Coverage
Standardized Models
Instructions
Changes to regulations and sub-regulatory guidance have resulted in the Annual Notice of
Change (ANOC) and the Evidence of Coverage (EOC) becoming two independent (stand-alone)
documents with different delivery requirements and flexibilities. They are no longer a combined
document for Contract Year (CY) 2019. The 2019 stand-alone ANOC and stand-alone EOC are
standardized models and must be used by all Medicare Advantage Organizations (MAOs),
Medicare Prescription Drug Plans (PDPs), and section 1876 Cost Plans exactly as provided,
unless otherwise indicated below and/or in the instructions in the ANOC and the EOC models.
CMS may conduct retrospective reviews to ensure adherence to the models.
Permissible Alterations
The following are permissible alterations to the models:
1. Minor edits (e.g., grammatical or punctuation changes, updating/correcting phone
numbers, correcting references) as necessary.
2. Formatting (e.g., font style, margins) that meets CMS Medicare Communications and
Marketing Guidelines (MCMG) (formerly Medicare Marketing Guidelines) and other
CMS guidance.
3. Recreating graphics and/or tables for style and format that meets CMS MCMG and other
CMS guidance. However, the standardized text must be used in the same order as the
standardized document.
4. Adding plan logos.
5. Renumbering chapters and sections if chapters or sections are omitted or added (when
permitted).
6. Inserting MAO name or “we,” “our,” “us,” “the plan,” “our plan,” or “your plan” where
the document indicates “[insert plan name].” In addition, “we,” “our,” “us,” “the plan,”
“our plan,” or “your plan” may be used interchangeably even when one is already used in
the model.
7. Indicating when the Low-Income Subsidy (LIS) Rider was mailed separately in the LIS
Rider references.
8. Replacing references to broad organization names (e.g., State Health Insurance
Assistance Program (SHIPs), Quality Improvement Organizations (QIOs), State
Pharmaceutical Assistance Programs (SPAPs)) with the state-specific name in the
product service areas. If the broad organization name is used throughout the document,
the document must refer the beneficiary to Chapter 2 for information on his/her state
program.
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9. Cost Plans offering Part D as a separate and distinct optional supplemental benefit may
list the Part D premium amount separately within the ANOC and EOC.
10. Cost Plans not offering Part D benefits should modify or delete all references to Part D
benefits and the Part D late enrollment penalty.
11. Multiple benefit packages may be included within one EOC, but must be clearly
differentiated from one another to ensure that enrollees easily understand the information
for the plan in which they are enrolled.
If multiple benefit packages are included in one EOC, they must be benefit packages for
the same plan type and all either offer, or not offer, Part D coverage. Examples:
a. All MA-only HMOs, or all MA-PD HMOs may be included in one EOC.
b. An MA-only HMO may not be included with an MA-PD HMO, and an MA-only
HMO could not be included with an MA-only or MA-PD PPO.
Note: Plans may not combine multiple benefit packages in one ANOC. Each ANOC
must be specific to an enrollee’s plan.
12. MAOs, PDPs, and Cost Plans sending EOCs to new enrollees with effective dates of
January 1 and later may edit the document to remove all references to the ANOC (even if
not bracketed), since only the EOC must be distributed to these enrollees.
Modifications or Deletions of Standardized Language
The following are permissible modifications to, or deletions of, the model language:
1. When populating the models, delete instructions to plans.
2. Modify or delete, as necessary, all references under “all Plan Types” not relevant to your
plan.
3. If your organization uses an open access model, modify or delete, as necessary, all
references to primary care providers (PCP), referrals, etc.
4. If your organization does not offer a Part D benefit package, modify or delete, as
necessary, all references to Part D benefits.
5. Health Maintenance Organization Point of Service (HMO-POS) plans should modify
language related to network providers, as necessary, to clarify when a POS benefit may
furnish coverage.
6. References to Member Services, the Pharmacy Directory, the Provider Directory, the
Membership Identification (ID) card, and the List of Covered Drugs (Formulary) may be
changed to the term used by the MAO, PDP, or Cost Plan.
7. All references to TTY should be changed to TDD or TTY/TDD, if necessary, to reflect
the plan’s communication technology.

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8. MAOs, PDPs, or Cost Plans offering Part D benefits that do not include step therapy on
any of their formulary drugs should delete all references to step therapy.
Submissions to HPMS
The following are instructions for submitting materials into HPMS:
1. Unpopulated models may not be submitted into HPMS. Your organization must submit
an ANOC (if applicable) and an EOC for each Contract/Plan Benefit Package (PBP)
offered and must include all applicable premiums, cost-sharing, and benefit information
in the document. Each contract/PBP that is required to produce materials in alternate
languages (e.g., Spanish, Russian) must upload the ANOC and the EOC in every required
language using the Alternate Format functionality.
2. If MAOs, PDPs or Cost Plans split the EOC into two or more files (e.g., different files for
different sections), all sections must be submitted as one document/file.
3. ANOCs must be submitted as File & Use. EOCs must be submitted as Non-Marketing.
ANOCs and EOCs may be distributed immediately following submission in HPMS (no
5-day required waiting period).
4. MAOs, PDPs or Cost Plans that have consolidated plans should include, in one “zipped”
file, the ANOCs for both plans for the stand-alone ANOC submission. The zipped file
for the stand-alone ANOC submission should be uploaded under the remaining PBP. For
example, H0001 is consolidating PBP 001 into PBP 002 for CY2019. One zipped file
should be uploaded into HPMS under H0001 PBP 002 for the stand-alone ANOC. This
zipped file should have the ANOC for PBP 001 and the ANOC for PBP 002. For
consolidated plans, the stand-alone EOC should be submitted for the remaining
consolidated plan. Using the example above, the stand-alone EOC, should be submitted
for PBP 002. To help identify the zipped ANOCs, organizations must use the following
naming convention for all zipped ANOC files: The word “ANOC” followed by an
underscore; the Plan’s/Part D sponsor’s contract or MCE number, (i.e., “H” for MA or
Section 1876 Cost Plans, “R” for Regional PPO plans (RPPOs), “S” for PDPs, or “Y” for
Multi-Contract Entity (MCE) identifier) followed by an underscore; any series of alpha
numeric characters (Plan/Part D sponsor discretion) followed by an underscore; and an
uppercase “C” for communication materials or an uppercase “M” for marketing materials
(for example: H1234_abc123_C or H5678_efg456_M).
5. The “No Longer in Use” button should not be selected for ANOC and EOC submission.
A new “replacement” functionality will be available for plans to submit updated
materials.
6. The ANOC and EOC must be submitted using the following material submission codes:
Material

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Code
Submission

ANOC (applicable to all renewing PBPs)

1140

EOC (applicable to all PBPs) – Submission 1150
is required in HPMS even though the EOC
is a non-marketing material.
Input of Actual Mail Dates
MAOs, PDPs, and Cost Plans must input the actual mail dates (AMDs) in HPMS within 15 days
of mailing the ANOC. For instructions on technical aspects of submitting, refer to the Update
Material Link/Function section of the Marketing Review Users Guide in HPMS. When entering
the AMDs, please note the following requirements:
1. Enter the AMDs for only the ANOC mailings to existing enrollees. Plans are no longer
required to enter AMDs for EOC mailings to new and existing enrollees. (Do not enter
AMDs for October 1, November 1, December 1, or January 1 effective enrollment dates.)
2. If a renewing PBP has no existing enrollees, input the submission date as the AMD and
enter “1” for number of beneficiaries. HPMS does not accept “0” in the “#Beneficiaries”
field.
3. If another version, (e.g., non-English) was submitted as an Alternate Format for the
purpose of making it available upon the enrollee’s request, input the submission date as
the AMD and enter “1” for number of beneficiaries. HPMS does not accept “0” in the
“#Beneficiaries” field.
4. If both the original (English) and alternate versions are mailed, enter the AMD and
number of beneficiaries in the corresponding material submission. This is applicable to
MAOs, PDPs, and Cost Plans that maintain a list of enrollees who have requested to
receive an alternate version instead of the English version.
5. If all mailed documents are in the alternate format, MAOs, PDPs, and Cost Plans should
input the submission date as the AMD for the English version and enter “1” for number
of beneficiaries. HPMS does not accept “0” in the “#Beneficiaries” field.
Multiple ANOC and EOC Material Versions
Plans/Part D Sponsors are permitted to use the SA/LIS functionality to upload a different version
(not correction) of the original ANOC and EOC material submission. For example, if a plan
covers two states, the ANOC and EOC for one state would be submitted as the original
submission, and then the SA/LIS functionality would be used to submit the ANOC and the EOC
for a second state.
The initial document must be submitted into HPMS before additional versions are submitted
under the SA/LIS functionality. Please refer to the HPMS Marketing Module User’s Guide for
information on how to submit a document using the SA/LIS functionality.

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Medicare Rate Adjustments
Errata sheets should not be submitted when Plans/Part D Sponsors update the current year’s
Medicare amounts to mirror the Medicare amounts for enrollee cost sharing. The
updated/replaced functionality below should be used to update documents for Medicare FFS
rates.
Updated/Replaced ANOC and EOC
CMS modified HPMS to allow for an updated ANOC and EOC to account for changes, such as
Medicare FFS rates, changes in policies, and changes in address/phone number. Details about
the new “replacement” functionality is provided in the HPMS Marketing Module User’s Guide.
Mailing Requirements
1. All Plans/Part D Sponsors and cost plans must send the following for enrollee receipt no
later than September 30:
 Stand-alone ANOC
 LIS Rider
2. All Plans/Part D Sponsors and cost plans must provide the EOC (either hard copy or
electronically) for enrollee receipt no later than October 15. Plans have the following
options:
 Send the hard copy EOC with the ANOC
 Send the hard copy EOC for receipt by October 15
 Provide the EOC electronically by October 15 (see requirement 3)
Note: Due dates for D-SNPs have changed. The ANOC is still due for member receipt
by September 30. The EOC must be provided by October 15. D-SNPs are no longer
required to mail the Summary of Benefits with the ANOC, but may do so. D-SNPs must
follow the ANOC and EOC mailing instructions provided in this section.
3. If a Plan/Part D Sponsor chooses to deliver the EOC electronically, they must provide a
notice (referred to as “Notice”) to enrollees providing them with the following
information:
 Notification that the electronic EOC will be available by October 15
 State how to access the electronic EOC (e.g. URL address)
 State how to request a hard copy (e.g. phone number, online link)
Note: CMS recommends that Plans/Part D Sponsors mail the Notice with the ANOC.
This will reduce mailing costs and avoid beneficiary confusion. Plans/Part D Sponsors
should submit the Notice zipped with the EOC in HPMS.
This Notice can be combined with the notice required when Plans/Part D Sponsors
deliver provider directory/pharmacy directories and formularies electronically (as
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articulated in Chapter 4 and the HPMS memo entitled, “Pharmacy Directories and
Disclaimers” August 16, 2016).
4. See below for due dates for enrollees with enrollments effective October 1, November 1,
December 1, and January 1.
Enrollee
Effective
Date

Current Year EOC
(hard copy or notice)

Upcoming Year ANOC
(hard copy only)

October 1

Within ten (10) calendar
days from receipt of
CMS confirmation of
enrollment, or by the last
day of the month prior to
the effective date,
whichever is later

Within ten (10) calendar October 15
days from receipt of CMS
confirmation of
enrollment, or by the last
day of the month prior to
the effective date,
whichever is later

November 1
December 1

Within ten (10) calendar
days from receipt of
CMS confirmation of
enrollment, or by the last
day of the month prior to
the effective date,
whichever is later

Within ten (10) calendar
days from receipt of CMS
confirmation of
enrollment, or by the last
day of the month prior to
the effective date,
whichever is later

Within ten (10) calendar
days from receipt of CMS
confirmation of
enrollment, or by the last
day of the month prior to
the effective date,
whichever is later

January 1

N/A

N/A

Within ten (10) calendar
days from receipt of CMS
confirmation of
enrollment, or by the last
day of the month prior to
the effective date,
whichever is later

and

Upcoming Year EOC
(hard copy or notice)

5. Plans/Part D Sponsors may include the following in the ANOC mailing: the Notice,
Summary of Benefits, Provider Directory, Pharmacy Directory, EOC, LIS Rider, the
formulary and a form allowing enrollees to “opt-in” to receiving their upcoming ANOC and
EOC via e-mail. Unless otherwise directed, no additional plan communications may be
included in the mailing.

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Other than providing the SB with the ANOC, Plans/Part D Sponsors may not highlight benefits
or information regarding upcoming 2019 plan activities in the ANOC, the EOC, or the Notice.
Employer-Sponsored Group Plans
MAOs, PDPs, and Cost Plans offering employer-sponsored group plans (including
employer/union-only group waiver plans (EGWPs) or individual plans sponsored by employer/
union groups) are subject to all applicable dissemination, disclosure and timing requirements,
unless specifically waived or modified. Refer to the Medicare Managed Care Manual (Chapter 9)
and the Prescription Drug Benefit Manual (Chapter 12) for more detailed information concerning
EGWPs and applicable waivers/modifications. Please note the following employer group
waivers/modifications as they relate to the requirements included in these instructions:
1. ANOC and EOC documents do not have to be submitted into HPMS. However, they
must be made available to CMS upon request.
2. The required ANOC and EOC language may be customized to more clearly describe the
benefits available to employer/union group plan enrollees.
3. Materials must reflect the actual premium amount the enrollee pays, including any
supplemental coverage and any corresponding employer/union premium subsidy. If the
amount the enrollee actually pays is not available, the organization may use the
standardized model language in lieu of providing the actual premium amount (e.g.,
“contact your employer group plan benefit administrator”).
4. If CMS has waived/modified the timing requirements for mailing the ANOC and EOC,
such as when an employer/union group plan has a different open enrollment period from
Medicare, both the ANOC and EOC must be received no later than 15 days before the
employer/union group plan’s open enrollment period begins.
5. Employer-sponsored group plans do not need to enter AMD information.

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