For the 2021 contract year, based on 60-day Federal Register public comments from the Paperwork Reduction Act (PRA) and feedback from CMS subject matter experts (SMEs), Annual Notice of Change (ANOC) and Evidence of Coverage (EOC) models have been revised to reflect policy changes and simplify information for plan members. The nine ANOC and nine EOC models are separated into 18 plan specific models (Cost-based plans, D-SNP, HMO-MA, HMO-MAPD, MSA, PDP, PFFS, PPO-MA, and MAPD). The changes will not result in additional burden. Plan sponsors will still be required to use the standardized language and send the ANOCs to members by September 30, 2020 and EOCs to members by October 15, 2020. The table below summarizes the edits.
Clarification Requested By |
Chapter/Section |
Change/Reason |
CMS |
Cover Page About Section Section 1 Section 4.2 |
In ANOC and EOC, inserted optional text to allow addition of Doing Business As (DBA) names to organization names. |
CMS |
Throughout model |
In ANOC and EOC, shortened website links by removing “https//”. |
CMS |
Throughout model |
In ANOC and EOC, removed capitalization of "Braille" to "braille". |
Clarification Requested By |
Chapter/Section |
Change/Reason |
CMS and Public Response |
What to do now, Compare Section Section 4.2 Section 8.2 |
In ANOC, updated the Medicare Plan Finder link and removed instructions to click on "Find health & drug plans". |
Public Response |
'What to do now' Section 4. ENROLL: |
In ANOC, added language to inform members that they will be automatically disenrolled from the plan if they join another plan during open enrollment. |
CMS |
Section 1 |
In ANOC, updated language to "If you want to change plans, you can do so between October 15 and December 7." |
Public Response |
Additional Resources Section |
In ANOC, added “member services” to Member Services number for consistency. |
Public Response |
Section 4.2, Step 2: Change your coverage |
In ANOC, formatted the word “change” to bold text. |
Clarification Requested By |
Chapter/Section |
Change/Reason |
Public Response |
Chapter 7, Section 5.1 (MSA, HMO MA, PPO MA, PDP); Chapter 9, Section 5.1 (HMO MAPD, PPO MAPD, Cost Plan, PFFS); Chapter 9, Section 6.1 (HMO MAPD, PPO MAPD, Cost Plan, PFFS); Chapter 9A and 9B, Section 6.1 (D-SNP); Chapter 9A and 9B, Section 7.1 (D-SNP); |
In EOC, revised the questions to statements in the table for clarification. |
CMS |
Throughout model |
In EOC, replaced “independent organization” and “independent outside organization” with “Independent Review Organization”. |
Public Response |
Chapter 7, Section 4.2 (MSA, HMO MA, PPO MA, PDP); Chapter 9, Section 4.2 (HMO MAPD, PPO MAPD, Cost Plan, PFFS); Chapter 9A and 9B, Section 5.2 (D-SNP) |
In EOC, updated bulleted language in section for consistency. |
CMS |
Chapter 7, Section 7.1 (PDP); Chapter 7, Section 9.1 (MSA, HMO MA, PPO MA); Chapter 9, Section 10.1 (HMO MAPD, PPO MAPD, Cost Plan, PFFS); Chapter 9A and Chapter 9B, Section 11.1 (D-SNP) |
In EOC, added the word “coverage” to the sentence. |
CMS |
Chapter 7, Section 7.4 (PDP); Chapter 7, Section 9.4 (MSA, HMO MA, PPO MA); Chapter 9, Section 10.4 (HMO MAPD, PPO MAPD, Cost Plan, PFFS); Chapter 9A and Chapter 9B, Section 11.4 (D-SNP) |
In EOC, removed “to us” from the sentence. |
CMS |
Chapter 7, Section 6.1 (PDP); Chapter 7, Section 8.1 (MSA, HMO MA, PPO MA); Chapter 9, Section 9.1; (HMO MAPD, PPO MAPD, Cost Plan, PFFS); Chapter 9A and 9B, 10.1 (D-SNP) |
In EOC, changed header from “Levels of Appeal 3, 4, and 5 for Medical Service Appeals” to “Appeal Levels 3, 4 and 5 for Medical Service Requests”. |
CMS |
Chapter 7, Section 7.3 (PDP); Chapter 7, Section 9.3 (MSA, HMO MA, PPO MA); Chapter 9, Section 10.3(HMO MAPD, PPO MAPD, Cost Plan, PFFS); Chapters 9A and 9B, Section 11.3 (D-SNP) |
In EOC, added “with” to make the word “within”. |
Clarification Requested By |
Chapter/Section |
Change/Reason |
CMS |
Section 2.3 (PDP); Section 2.6 |
In ANOC, added new language “that otherwise meet the requirements,” related to replacing brand name drugs with their new generic equivalents. |
Public Response |
Section 2.3 (PDP); Section 2.6 |
In ANOC, deleted the word "we" from sentence. |
Public Response |
Section 2.3 (PDP); Section 2.6 |
In ANOC, deleted language regarding long term care supply. |
Public Response |
Section 2.3 (PDP); Section 2.6 |
In ANOC, separated paragraph regarding replacing brand name drugs with their new generic equivalents into two paragraphs for readability. |
Public Response
|
Section 2.3 (PDP); Section 2.6 |
In ANOC, removed language referring to phone numbers for Member Services. |
CMS |
Section 2.3 (PDP); Section 2.6 |
In ANOC, added “or both” to the sentence. |
Public Response |
Chapter 1, Section 7.1 |
In EOC, updated language for consistency and refer to either the premium or Part D late enrollment penalty (LEP) dollar amount values. |
CMS |
Chapter 1, Section 4.1 |
In EOC, added Part D IRMAA language including reference to Section 6. |
CMS |
Chapter 1, Section 4.1 (D-SNP) Chapter 1, Section 5.1 |
In EOC, added “other” in front of “creditable prescription drug coverage," as Part D is also considered to be creditable coverage. |
Public Response |
Chapter 5, Section 3.1 & 7.1; Chapter 3, Section 3.1 & 7.1 (PDP) |
In EOC, added Lexi-Drugs to the list of reference books used to support a medically accepted indication. |
CMS |
Chapter 10 (PDP); Chapter 12 |
In EOC, added language to Part D LEP definition. |
CMS |
Chapter 1, Section 4.3; Chapter 8, Section 3.1 (PDP); Chapter 10, Section 3.1 |
In EOC, added "for 63 days or more in a row" related to Part D LEP. |
CMS |
Chapter 4, Section 3.1 (PDP); Chapter 6, Section 3.1 |
In EOC, added new language regarding Part D drug pricing, including beneficiary information about prescription cost increases and other drugs that may be available to beneficiaries with lower cost sharing. |
CMS |
Chapter 1, Section 3.4 (PDP); Chapter 1, Section 3.5 |
In EOC, added language for new 2021 requirement for all Part D EOC model types referencing the Part D EOB. |
CMS |
Chapter 7, Section 5.4 (PDP); Chapter 9, Section 6.4 (HMO MAPD, PPO MAPD, Cost Plan, PFFS); Chapter 9A and 9B, Section 7.4 (D-SNP) |
In EOC, replaced “get a” with “ask for”. |
CMS |
Chapter 7, Section 5.1 (PDP); Chapter 9, Section 6.1 (HMO MAPD, PPO MAPD, Cost Plan, PFFS); Chapter 9A and 9B, Section 7.1 (D-SNP) |
In EOC, added “the pharmacy will give” and removed “will get”. |
CMS |
Chapter 10, Definition of Exception (PDP); Chapter 12, Definition of Exception |
In EOC, replaced the word “determination” with “decision”. |
CMS |
Chapter 3, Section 6.2 (PDP); Chapter 5, Section 6.2 |
In EOC, added “the”, “, or both”, and “or both”. |
CMS |
Chapter 3, Section 6.2 (PDP); Chapter 5, Section 6.2 |
In EOC, removed “new year’s” and added “in the new benefit year”. |
CMS |
Chapter 3, Section 10.2 (PDP); Chapter 5, Section 10.2 |
In EOC, added clarifying language about the Drug Management Program (DMP). |
CMS |
Chapter 3, Section 10.2 (PDP); Chapter 5, Section 10.2 |
In EOC, replaced “one” with “a certain” and added made pharmacy and doctor plural. |
CMS |
Chapter 3, Section 10.3 (PDP); Chapter 5, Section 10.3 |
In EOC, removed “For example, some members have several medical conditions, take different drugs at the same time, and have high drug costs”. |
CMS |
Chapter 3, Section 10.3 (PDP); Chapter 5, Section 10.3 |
In EOC, added language about the DMP and Medication Therapy Management (MTM) program. |
CMS |
Chapter 7, Section 5.3 (PDP); Chapter 9, Section 6.3; Chapter 9A and 9B, Section 7.3 (D-SNP) |
In EOC, added “or are likely to cause an adverse reaction or other harm”. |
CMS |
Chapter 7, Sections 5.4 and 5.5 (PDP); Chapter 9, Sections 6.4 and Section 6.5; Chapters 9A and 9B, Sections 7.4 and 7.5 (D-SNP) |
In EOC, replaced “to” with “you can” and added “our decision” in section 6.5. |
CMS |
Chapter 7, Section 5.4 (PDP); Chapter 9, Section 6.5; Chapters 9A and 9B, Section 7.5 (D-SNP) |
In EOC, replaced “tell” with “talk”. |
CMS |
Chapter 7, Section 5.6 (PDP); Chapter 9, Section 6.6; Chapters 9A and 9B, Section 7.6 (D-SNP) |
In EOC, bolded “within 14 calendar days”. |
Clarification Requested By |
Chapter/Section |
Change/Reason |
CMS |
Chapter 3, Section 8 |
In EOC, added new section 8 titled “Rules for Oxygen Equipment, Supplies, and Maintenance” including what is covered and details about Medicare oxygen equipment coverage cost sharing. |
CMS |
Chapter 7, Section 5.1 (MSA, HMO MA, PPO MA); Chapter 9, Section 5.1 (HMO MAPD, PPO MAPD, Cost Plan, PFFS); Chapter 9A and 9B, Section 6.1 (D-SNP) |
In EOC, removed "or services" throughout the section. |
CMS |
Chapter 7, Section 6.4 (MSA, HMO MA, PPO MA) Chapter 9, Section 7.4 (HMO MAPD, PPO MAPD, Cost Plan, PFFS); Chapter 9A and 9B, Section 8.4 (D-SNP) |
In EOC, added “whichever comes first". |
Public Response |
Chapter 3, Section 6.2 |
In EOC, rename the section from "What Care from a Religious Non-Medical Health Care Institution is Covered by our Plan?" to "Receiving Care from a Religious Non-Medical Health Care Institution". |
CMS |
Chapter 4, Medical Benefits Chart |
In EOC, added Acupuncture benefit in the Medical Benefits Chart. |
CMS |
Chapter 4, Section 3.1 |
In EOC, moved the check to the column "covered only under specific conditions" for Acupuncture. |
CMS |
Chapter 7, Section 5.1 (MSA, HMO MA, PPO MA) Chapter 9, Section 5.1 (HMO MAPD, PPO MAPD, Cost Plan, PFFS) Chapter 9A and 9B, Section 6.1 (D-SNP) |
In EOC, removed “or services” from sentences where applicable. |
CMS |
Chapter 7, Section 5.2 (MSA, HMO MA, PPO MA); Chapter 9, Section 5.2 (HMO MAPD, PPO MAPD, Cost Plan, PFFS); Chapter 9A and 9B, Section 6.2 (D-SNP) |
In EOC, replaced “get” with “ask for”. |
CMS |
Chapter 7, Section 5.2 (MSA, HMO MA, PPO MA); Chapter 9, Section 5.2 (HMO MAPD, PPO MAPD, Cost Plan, PFFS); Chapter 9A and 9B, Section 6.2 (D-SNP) |
In EOC, removed paragraphs regarding authorizing and providing medical care coverage. |
CMS |
Chapter 7, Section 5.3 (MSA, HMO MA, PPO MA); Chapter 9, Section 5.3 (HMO MAPD, PPO MAPD, Cost Plan, PFFS); Chapter 9A and 9B, Section 6.3 (D-SNP) |
In EOC, added “explain the reason your appeal is late when you make your appeal. We”. |
CMS |
Chapter 7, Section 5.3 (MSA, HMO MA, PPO MA); Chapter 9, Section 5.3 (HMO MAPD, PPO MAPD, Cost Plan, PFFS); Chapter 9A and 9B, Section 6.3 (D-SNP) |
In EOC, added the word “that” to the sentence. |
CMS |
Chapter 7, Section 5.3 (MSA, HMO MA, PPO MA); Chapter 9, Section 5.3 (HMO MAPD, PPO MAPD, Cost Plan, PFFS); Chapter 9A and 9B, Section 6.3 (D-SNP) |
In EOC, added “you have not yet received” and removed “if your appeal is about coverage for a Part B prescription drug you have not yet received”. |
CMS |
Chapter 7, Section 5.4 (MSA, HMO MA, PPO MA); Chapter 9, Section 5.3 (HMO MAPD, PPO MAPD, Cost Plan, PFFS); Chapter 9A and 9B, Section 6.3 (D-SNP) |
In EOC, added “if your request is for a medical item or service” and removed “, after we receive your appeal”. |
CMS |
Chapter 7, Section 5.4 (MSA, HMO MA, PPO MA); Chapter 9, Section 5.4 (HMO MAPD, PPO MAPD, Cost Plan, PFFS); Chapter 9A and 9B, Section 6.4 (D-SNP) |
In EOC, replaced “got” with “get”. |
CMS |
Chapter 3, Section 4.2 |
In EOC, added “these services” to the sentence. |
CMS |
Chapter 7, Section 6.1 (MSA, HMO MA, PPO MA); Chapter 9, Section 7.1 (HMO MAPD, PPO MAPD, Cost Plan, PFFS); Chapter 9A and 9B, Section 8.1 (D-SNP) |
In EOC, added “your right to” and replaced “it” with “the notice”. |
CMS |
Chapter 7, Sections 6.4 and 7.5 (MSA, HMO MA, PPO MA); Chapter 9, Sections 7.4 and 8.5 (HMO MAPD, PPO MAPD, Cost Plan, PFFS); Chapters 9A and 9B, Sections 8.4 and 9.5 (D-SNP); |
In EOC, removed “If we say no to your Level 1 Appeal, your case will automatically be sent on to the next level of the appeals process”. |
CMS |
EOC: Chapter 7, Section 8.1 (MSA, HMO MA, PPO MA); Chapter 9, Section 9.1 (HMO MAPD, PPO MAPD, Cost Plan, PFFS); Chapter 9A and Chapter 9B, Section 10.1 (D-SNP) |
In EOC, added “if the value of the item or medical service meets the required dollar value”. |
CMS |
Chapter 7, Sections 6.1 and 7.2 (MSA, HMO MA, PPO MA); Chapter 9, Section 7.1 and 8.2 (HMO MAPD, PPO MAPD, Cost Plan, PFFS); Chapter 9A and 9B, Section 8.1 and 9.2 (D-SNP) |
In EOC, replaced “must” with “will be asked to” and deleted “signed” where applicable. |
CMS |
Chapter 7, Section 6.3 (MSA, HMO MA, PPO MA); Chapter 9, Section 7.3; Chapter 9A and 9B, Section 8.3 (D-SNP) |
In EOC, removed “ed” from the word “stayed”. |
Clarification Requested By |
Chapter/Section |
Change/Reason |
CMS |
Chapter 1, Section 2.1 |
In EOC, removed language on the prohibition on ESRD individuals being allowed to enroll in MA plans |
Public Response |
Chapter 1, Section 3.1 |
In EOC, updated language about the Medicare card. |
Public Response and CMS |
Chapter 4, Medical Benefits Chart |
In EOC, added clarifying benefit language for additional telehealth services under Physician/Practitioner services, including doctor’s office visits. |
Clarification Requested By |
Chapter/Section |
Change/Reason |
Public Response |
Chapter 4, Medical Benefits Chart |
In EOC, added language in the "Medicare Part B Prescription Drugs" benefit to include statement regarding vaccine coverage. |
CMS |
Chapter 10, Section 2.2 (HMO MAPD, PPO MAPD, PFFS); Chapter 10, Section 2.3 (D-SNP); Chapter 8, Section 2.2 (HMO MA, PPO MA) |
In EOC, replaced "have until March 31 to" with "can also" and replaced "to add drug coverage" with "at that time". |
CMS |
Chapter 10 (HMO MA, PPO MA); Chapter 12 (HMO MAPD, PPO MAPD, D-SNP, PFFS) |
In EOC, revised Medicare Advantage Open Enrollment Period definition to clarify additional enrollment options available to beneficiaries between January 1 and March 31 and 3-months after an individual is first eligible for Medicare. |
Clarification Requested By |
Chapter/Section |
Change/Reason |
Public Response |
Section 2.1 |
In ANOC, added additional language to direct members to the appropriate section for more information. |
Clarification Requested By |
Chapter/Section |
Change/Reason |
CMS |
Chapter 8, Section 2.1 (PDP); Chapter 10, Section 2.1 (HMO MAPD, PPO MAPD, PFFS); Chapter 10, Section 2.2 (D-SNP)
|
In EOC, clarified timeframe for creditable prescription drug coverage and paying Part D LEP. |
Clarification Requested By |
Chapter/Section |
Change/Reason |
CMS |
Chapter 4, Section 2.1 |
In EOC, provided new Value Based Insurance Design Model Test (VBID) benefit information. |
Clarification Requested By |
Chapter/Section |
Change/Reason |
CMS |
Chapter 1, Section 7.2; Chapter 1, Section 4.1 (D-SNP); Chapter 1, Section 4.3 (D-SNP); Chapter 12 (D-SNP) |
In EOC, revised Extra Help language. |
CMS |
Chapter 9, Section 9.2; Chapters 9A and 9B, Section 10.2 and 10.3 (D-SNP) |
In EOC, replaced “Levels of Appeal 3, 4, and 5 for Part D Drug Appeals” with Appeal Levels 3, 4 and 5 for Part D Drug Requests”. |
Clarification Requested By |
Chapter/Section |
Change/Reason |
CMS |
ANOC: Section 2.3 EOC: Chapter 3, Section 2.3 |
In ANOC and EOC, replaced “and managing” with “to manage” in sentence. |
Clarification Requested By |
Chapter/Section |
Change/Reason |
CMS |
Chapter 7, Section 4.2 (MSA, HMO MA, PPO MA); Chapter 9, Section 4.2 (HMO MAPD, PPO MAPD, Cost Plan, PFFS) |
In EOC, added “or Part B prescription drugs”. |
Clarification Requested By |
Chapter/Section |
Change/Reason |
CMS |
Chapter 10, Section 1.1 |
In EOC, updated I-SNP language to “CCPs serving individuals who meet the definition of “institutionalized”: May”. |
CMS |
Chapter 10, Section 2 and 3 |
In EOC, updated I-SNP language for individuals who meet the definition of "institutionalized", added the word “may” where applicable, and removed extra nursing home language. |
Clarification Requested By |
Chapter/Section |
Change/Reason |
Public Response |
Chapter 9, Section 8.2 |
In EOC, revised section reference to 8.3 instead of 7.3. |
Clarification Requested By |
Chapter/Section |
Change/Reason |
CMS |
Chapter 10, Section 2.1 |
In EOC, replaced "a Special Enrollment Period" with "an enrollment period." |
CMS |
Chapter 4, Medical Benefits Chart |
In EOC, updated information to provide detail regarding telehealth services. |
Clarification Requested By |
Chapter/Section |
Change/Reason |
CMS |
Section 4.2 |
In ANOC, removed duplicative sentences about changing to Original Medicare. |
CMS |
Section 1 and Section 5 |
In ANOC, replaced “now” with actual date of “October 15” |
CMS |
Section 3 |
In ANOC, added “change in appeals and grievance procedures”. |
CMS |
Chapter 1, Section 4.2 |
In EOC, removed Part D LEP language beginning with "Plans without a monthly premium” and the paragraph following it. |
CMS |
Chapter 1, Section 4.2 |
In EOC, removed optional text “[plans without a premium insert: Part D late enrollment penalty]”. |
CMS |
Chapter 1, Section 4.3 |
In EOC, removed the bullet about paying the Part D LEP and being eligible for “Extra Help.” |
CMS |
Chapter 3, Section 4.2 |
In EOC, revised language to account for two types of D-SNPs that offer capitated Medicaid benefits. |
CMS |
Chapter 4, Section 2.1 |
In EOC, revised language to account for two types of D-SNPs that offer capitated Medicaid benefits and added “they cover” where applicable. |
CMS |
Chapter 8, Section 2.1 |
In EOC, removed language about paying a late enrollment penalty. |
CMS |
Chapter 9A, Section 12 |
In EOC, added language to sentence to be in accordance with 42 CFR 422.562(a)(5). |
Clarification Requested By |
Chapter/Section |
Change/Reason |
CMS |
Chapter 10, Section 3.1 |
In EOC, replaced "by" with "between October 15 and". |
CMS |
Chapter 4, Section 2.1 |
In EOC, removed VBID language. |
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | 2020 ANOC EOC Crosswalk for CMS Review |
| Subject | CMS ANOC EOC |
| Author | Booz Allen Hamilton |
| File Modified | 0000-00-00 |
| File Created | 2021-01-14 |