60 Day Crosswalk

Attachment_B_2021_ANOC_EOC_Crosswalk_03122020_CLEAN_with_no_issue_numbers_03162020.docx

Medicare Advantage and Prescription Drug Program: Final Marketing Provisions CFR 422.111(a)(3) and 423.128(a)(3) (CMS-10260)

60 Day Crosswalk

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Attachment B: 60-day Federal Register Crosswalk: High Level Summary of Revisions

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.

Plan Type: Changes to all ANOC and EOC Models

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".

Plan Type: Changes to all ANOC Models

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.

Plan Type: Changes to all EOC Models

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”.

Plan Type: All Part D

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”.

Plan Type: All except PDP

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”.

Plan Type: All except Cost Plan and PDP

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.

Plan Type: All except Cost Plan, MSA, and PDP

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.

Plan Type: All except D-SNP, MSA, HMO MA, and PPO MA

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.

Plan Type: All except Cost Plan, MSA, HMO MA, and PPO MA

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.

Plan Type: All except Cost Plan, PFFS, MSA and PDP

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.

Plan Type: All except MSA, HMO MA, PPO MA, and PDP

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”.

Plan Type: All except MSA and PDP

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.

Plan Type: All except D-SNP and PDP

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”.

Plan Type: HMO MAPD and PPO MAPD

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.

Plan Type: HMO MAPD

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.

Plan Type: Cost Plan

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.

Plan Type: D-SNP

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).

Plan Type: PFFS

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 Typeapplication/vnd.openxmlformats-officedocument.wordprocessingml.document
File Title2020 ANOC EOC Crosswalk for CMS Review
SubjectCMS ANOC EOC
AuthorBooz Allen Hamilton
File Modified0000-00-00
File Created2021-01-14

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