This growing market segment represents a big opportunity for Medicare Advantage Organizations.

According to a recent report by Kaiser Family Foundation, Medicare spending is expected to double in the next 10 years with similar growth expected in Medicare membership. According to the Centers for Medicare & Medicaid (CMS), one in three Medicare enrollees selects a private Medicare Advantage plan.

This growing market segment represents a big opportunity for Medicare Advantage Organizations (MAOs) that are prepared to take advantage of it. That said, the rigorous demands presented by the regulatory controls and requirements surrounding CMS mandated customer plan materials such as the Annual Notice of Change, Evidence of Coverage, Summary of Benefit, and related materials make it increasingly challenging to scale and expand product offerings efficiently.

In a recent poll conducted by Messagepoint, MAOs identified the following issues associated with managing these materials:

  • Missed deadlines & late submissions–Due to the complexity of making the annual changes required by CMS, responding to last minute changes by CMS
  • Employee burnout–Due to manual processes in making complex CMS model and data requirement changes
  • Document quality challenges–Compliance issues and inconsistencies between plan submissions are extremely common leading to errata, fines, and rework
  • High costs–Manual approaches or service provider led approaches do not support economies of scale–as the number of plans grows, costs grow at the same rate
  • Inability to scale–The manual approach to managing these documents has prevented organizations from moving forward with the expansion of plan offerings

These issues are directly impacted by the approach leveraged to manage these complex, regulated documents.

Document management approaches directly impact success

MAOs typically rely on one of three approaches to manage their documents.

Approach 1: Manual methods

It isn’t uncommon for MAOs to rely on manual approaches to create each plan document individually, leveraging copy-paste, manual edits, and even MS Word-based mail merges. This approach is fraught with issues including errors, missed deadlines, burnout, and an inability to scale. Organizations have one lever to grow their business or improve success rates when using this approach and that is to “throw more people at the problem.” Not only is this an ineffective and costly approach, but it also doesn’t allow for economies of scale as an MAO grows its plans to serve new market segments.

Approach 2: Outsourcing

MAOs often outsource this work to external vendors to complete. These vendors often still complete much of the work manually introducing many of the same issues with the internal manual approach. This costly model limits an organization’s ability to scale – as plans grow, costs grow at the same rate and charges are incurred for every change and click.

Approach 3: Adoption of document generation software

Many MAOs have started to leverage software offerings to address the challenge of document generation. Many of these products can provide some efficiencies, but the level to which they improve processes varies widely. The vast majority of these tools provide a blank starting point for the MAOs, forcing them to implement complex CMS models, plan data, business rules, translations, and 508 compliance requirements.

How to address the challenges

Because quality, scalability, and cost efficiency are so strongly tied to the management approaches applied to the creation and management of these documents, MAOs must search for solutions that address the key challenges that are holding their business back.

MAOs should look for software solutions that provide the following capabilities:

  • Pre-built documents–Pre-built documents that provide the CMS layouts and latest model content, and complex CMS rules per the latest regulations offer a starting point for both English and Spanish versions of your plans. This greatly reduces the time and effort to build plan documents and is a key contributor to enabling organizations to have more time for QA, ultimately enabling teams to finish their work early.
  • PBP data integration–By leveraging your existing PBP data, you can rest assured that your plan documents will match bid submissions and you will be able to generate fully compliant CMS outputs immediately.
  • Advanced content sharing–Ensure that you can centrally manage plan content as shared content objects that are separate from layouts to create efficiencies in creating and maintaining multiple plans. By taking this approach over creating and maintaining content in individual documents you will be able to make a change to a content object and have it instantly appear everywhere that object exists i.e., won’t have to make the same content changes in each individual document repeatedly. This approach also enables you to respond quickly to last-minute changes that are always challenging. You should also look for options that enable you to dynamically target and customize content & messaging for different business segments.
  • Collaboration–Look for the ability to enable multiple users to be able to work on chapters, sections, benefits simultaneously during editing, review & approvals.
  • Automate 508 compliance–508 compliance should be automatic so that when you generate the output, it is 508 compliant across multiple languages and also generates dynamic large print versions of your content.
  • Rigorous QA processes–Accuracy is vital and it is essential to have both change management tracking and QA capabilities that support and simplify the process. Key capabilities to look for include the ability to do side-by-side comparisons of differences between two versions of a document, add annotations and identify defects.
  • Cloud-based–Leveraging a browser-based solution that is hosted by your vendor greatly reduces the cost and management requirements of your organization. 


    MAOs that leverage a purpose-built platform for managing these highly regulated, complex plan materials have been able to finish early, with less stress, and higher quality, easily navigating the annual changes from CMS and expanding their plan offerings.

    Messagepoint’s Healthcare Touchpoint Exchange is a purpose-built solution to streamline the creation and annual updates to your CMS compliance materials including Annual Notice of Change (ANOC), Evidence of Coverage (EOC), Summary of Benefit (SB) and other documents.  Our unique approach enables customers to finish materials early with greater accuracy to meet their AEP goals. For more information, visit