How to Conduct a Compelling , Comprehensive , and Compliant Care Improvement Plus Appointment

1. How to Conduct a Compelling, Comprehensive, and Compliant Care Improvement Plus Appointment Brandon Clay, Senior Director of Sales September 30, 2010

2. Compelling—a unique Medicare Advantage plan that provides specialized care based upon personal needs Comprehensive—providing a complete and thorough review of the plan’s benefits and rules Compliant—regulatory environment requires deep understanding and consistent obeyance of the laws/rules set forth by all Federal (CMS) and State (DOI) entities Compelling, Comprehensive, and Compliant

3. Care Improvement Plus Appointment • Generating a “lead”/Setting an appointment • Conducting an appointment • “Best practices” for enrollment follow up

4. CMS, DOIs, and Care Improvement Plus are focused on how a lead/appointment is secured You are personally responsible for every lead/appointment During the course of an audit or investigation you likely will be asked to provide documentation as to the source of the lead Generating a (Compliant!) Lead

5. CMS/Plan approved marketing materials CMS/Plan-approved, plan-specific materials Plan-approved generic materials These materials may take the form of: Direct mail Advertising Phone scripts Contact with Existing Customers Sold into and currently enrolled in another Medicare health plan Sold non-health related insurance product (e.g. life, burial, dental) Permissible Lead Generation

6. ALL Marketing Materials All marketing materials (even those approved for use by other health plans and/or CMS) must be submitted to Care Improvement Plus for prior review and approval if their use may result in a Care Improvement Plus enrollment. Examples include: business reply cards, fliers, print ads, scripts, etc. All materials must be submitted by email to the following address: compliancereview@careimprovementplus.com Plan mention or benefit-specific information will require filing with CMS

7. Unsolicited contact Calls can only be made to prospects who initiate the contact (e.g. via reply card or inbound telephonic inquiry) This includes electronic voicemail messages, or answering machine messages Prohibited Lead Generation

8. Prohibited Lead Generation Sales Agents are NOT permitted to: Call former members who have voluntarily disenrolled or current members in the process of disenrolling to market plans or products. Call beneficiaries to confirm receipt of mailed information. Approach beneficiaries in common areas (e.g. parking lots, hallways, lobbies, etc.). Call or visit beneficiaries who attended a sales event, unless the beneficiary gives express permission at the event for a follow-up call or visit.

9. If you are obtaining sales leads from a third party and they cannot produce documentation to confirm that the lead was produced in a compliant manner, do not follow up to the lead if you believe it to be gathered in a non-compliant fashion. Third-Party Lead Generation

10. Pre-Appointment • Calling a beneficiary who has requested contact to set/confirm an appointment is compliant and Care Improvement Plus would recommend it as a best practice • If a Scope of Appointment has not been secured already, gather a Scope of Appointment at this time

11. Scope of Appointment • The scope of the appointment must be agreed upon by the prospective enrollee either in writing or recorded call at least 48 hours prior to the appointment. • The agreement must be documented by the Sales Agent or health plan when scheduling the appointment. Sales Agents can document the scope of appointment in writing via a signed scope of appointment form • If the scope of appointment is being documented by recording a phone call in advance of the appointment, the call must be placed by the plan sponsor and Not the agent/broker • If it is not feasible for the Scope of Appointment form to be completed prior to the appointment, the sales agent may have the beneficiary sign the form at the beginning of the appointment. • If it is not feasible for the Scope of Appointment form to be obtained prior to the appointment, you may have the prospect sign the form at the beginning of the appointment; however you are required to submit documentation to Care Improvement Plus as to why it was not feasible to obtain the Scope prior to the appointment.

12. Scope of Appointment 12 • In a case where the beneficiary has agreed to an appointment to discuss a PDP product, an agent cannot discuss an MA product during that same meeting unless the beneficiary requests it. • When a beneficiary asks to discuss another (MA) product type, the agent must have the beneficiary sign a new Scope of Appointment form for the new product type and then may continue the marketing appointment.  • A new separate appointment is not required and the 48 hour waiting period does not apply.

13. Examples 13 The following is an example of an unacceptable process: • A Sales Agent purchases a list of Medicare beneficiaries. The Sales Agent then calls each beneficiary on the list to see if they are interested in seeing what Medicare Advantage health plans are available to them. The following is an example of an acceptable process: • Mrs. Jones schedules an appointment with a Sales Agent/Broker to discuss MA-PD products. During the appointment, Mrs. Jones states that she would also like to purchase life insurance. The Sales Agent/Broker explains to Mrs. Jones that he can assist her with purchasing a life insurance policy but that he will have to schedule a separate appointment to come back and discuss life insurance options with her. • Only if Mrs. Jones insists that the non-MA product is represented at that time is it permissible to proceed with review of the non-MA product

14. Important Clarification 14 • An agent who is meeting with a Medicare beneficiary to discuss a non-Medicare Advantage product or service may establish a sales appointment for a Medicare Advantage product if the beneficiary or a caregiver initiates the request for information and if the  agent's and the lead generation organization's motivation for the original appointment was solely to market the non-Medicare Advantage product. • CMS policy is clear that an agent's motivation for the initial appointment, and any preceding contact arranging the appointment such as an outbound call, needs to be to market the non-MAPD product. • If the beneficiary requests information on Care Improvement Plus, the agent (1) must obtain a signed scope of appointment form and (2) schedule the Medicare Advantage appointment at least 48 hours after the non-MAPD appointment. • Only if the beneficiary insists that Care Improvement Plus is represented at that time is it permissible to proceed with review of the plan

15. Introduction Eligibility Assessing the “Best Fit” plan option Coverage Review Care Improvement Plus’ unique selling proposition Benefits Rules Enrollment Application Other administrative Wrap up The Appointment

16. Sales presentation introduction Provide name The organization represented Reminder of the purpose of the appointment Do not: Communicate or imply that you are a representative of—or affiliated with—Medicare (CMS) Introduction

17. Eligibility • General eligibility requirements to enroll a Medicare beneficiary: • Must be enrolled in Medicare Part A and enrolled in Medicare Part B • Must continue to pay the monthly Medicare Part B premium, unless it is otherwise paid for under Medicaid or by a third party. • Must live in the plan’s service area • Must complete the enrollment form during an applicable enrollment period • C-SNP Must have one of the qualifying chronic conditions: Diabetes and/or Heart Failure • D-SNP Full dual - $0 A/B cost-share • Best practice: If uncertain of member’s Medicaid status, call the Broker Advocate Team to check Medicaid eligibility

18. Assess the prospective member’s needs Review existing coverage Financial situation Medicaid LIS Healthcare needs Chronic conditions diabetes and/or heart failure Medical needs Prescription drug needs Review of Rx drug needs against formulary “Best Fit” Plan

19. “Best Fit” Plan

20. Coverage Review—Benefits Monthly premium Many of our plans are $0 premium Be sure to account for subsidy level when quoting monthly premium Out of pocket maximum Out of pocket maximum should not be of concern to a full dual beneficiary (as they do not accumulate A/B cost sharing) A/B benefits and any associated cost-sharing Deductibles, copays/co-insurance associated with A/B coverage are covered by State Medicaid for full duals Be sure to account for subsidy level when quoting A/B cost-sharing

21. Coverage Review—Benefits Prescription Drug (Part D) benefit Formulary review Best practice: have the beneficiary provide a list, or pull out all of their Rx drugs Be sure to account for Low Income Subsidy (LIS) level when quoting Part D cost sharing Review of Coverage Gap Remember: those with LIS do not encounter the Coverage Gap—they continue to pay their LIS co-pay levels For those without LIS 7% discount on generics in the Coverage Gap 50% discount on brands in the Coverage Gap

22. Coverage Review—Benefits Additional Care Improvement Plus Benefits and Services NOT offered by Original Medicare NOT offered by most other Medicare Advantage plans

23. Coverage Review—Benefits Additional Benefits and Services Benefits Vision Routine eye exam Glasses/contacts ($150-$200 annually) Dental Preventive dental (exams, x-rays, etc.) Dentures (available in our plans for full duals) Transportation (12-60 one-way rides) OTC (available in our Silver Rx plan) 24/7 Nurse Hotline

24. Coverage Review Care Management Programs HouseCalls Offers members an in-person visit with a physician or nurse practitioner who performs a health assessment to: Gather information to help us provide additional health education and care coordination Identify urgent health problems or risks Provide advice on topics to discuss at the next appointment with their regular doctor Occurs annually or more frequently upon need Within the past year, Care Improvement Plus has conducted more than 45,000 HouseCalls visits – more than any other Medicare health plan.

25. Coverage Review Care Management Programs PharmAssist Specialist Pharmacists provide: Personalized, private counseling Review of medications Education and support Many Care Improvement Plus members regularly take between 8-11 different medications– for these individuals, the PharmAssist program helps make managing medications more effective, safer, easier and less costly.

26. Coverage Review Care Management Programs Social Service Coordinators (SSC) Conducts outreach to members to determine eligibility for state, local, and federal programs that can assist with expenses, such as: Medicare Savings Programs (Medicaid) “Extra Help” or Low Income Subsidy (LIS) “Golden Touch” with local programs Pharmaceutical Assistance Program Telephone, heating and electric bills Meals Transportation

27. Coverage Review Care Management Programs Social Service Coordinators provides significant savings and valuable programs to our members. Social Service Coordinators: Will save Care Improvement Plus members more than $4 million in Part B premiums in 2010 Has enrolled or helped maintain more than 3,500 Care Improvement Plus members into State Medicaid programs whereby they will no longer have to pay their A/B cost sharing Enrolled more than 1,500 Care Improvement Plus members in LIS, saving them more than $6 million in prescription drug costs annually Enrolled Care Improvement Plus members in more than 25,000 community-based programs through its GoldenTouch outreach – bringing Care Improvement Plus members more than $30 million in valuable services annually

28. Coverage Review—Rules Open Access Network—go to any Medicare-approved provider who accepts payment from the plan With an open access network, members may go to any Medicare-approved provider that accepts payment from the plan. For DSNP, providers must accept both Medicare & Medicaid The plan will pay current Medicare rates to any Medicare provider with only a few exceptions (for example, transportation and pharmacy) where benefits are limited to a contracted network.  There are some providers who refuse to accept assignment from health plans, particularly Medicare Advantage plans.  These providers are generally not singling out Care Improvement Plus members, but have taken the position that they do not work with certain types of programs.  If a Sales Agent learns that a provider will not accept Care Improvement Plus, they are asked to bring this to the attention of the plan by calling Agent Support Hotline. Agents must emphasize that not all health care providers accept the health plan.  Care Improvement Plus will conduct outreach to providers who do not accept the plan—and, can provide the beneficiary with alternative health care providers if necessary.

29. Coverage Review—Rules Care Improvement Plus does not require referrals for access to specialists or other providers for Medicare-covered services. Members may always self-refer to a provider, without a referral or approval in advance for Medicare-covered benefits. Review of non-covered services (e.g. those not covered by Original Medicare unless covered by the plan, not “medically necessary”, etc.) The beneficiary is responsible for charges associated with non-covered services Review of services that require prior authorization (e.g. Inpatient hospital, SNF, etc.)

30. Marketing/Sales Events Webinar has focused on the Personal/Individual Marketing Appointment Separate set of rules govern Marketing/Sales events If you have questions re: Marketing/Sales events, ask your Sales Manager or email compliancereview@careimprovementplus.com

31. Important Reminders Individuals who currently have Medicare Advantage (MA), Medicare Advantage Part D (MA-PD) or Part D coverage are AUTOMATICALLY dis-enrolled from their plan by CMS upon their effective date with Care Improvement Plus. Individuals who currently have a Medicare Supplement (Medigap) coverage may keep it, but they CANNOT use it once they join Care Improvement Plus. Care Improvement Plus is NOT a Medicare Supplement (Medigap) plan. Care Improvement Plus is NOT a “stand-alone” Part D Plan.

32. Thank you in advance for representing Care Improvement Plus’ 2011 plan options in a compelling, comprehensive, and compliant manner! Questions?