Implementing High-Volume Accessible Medicare Document Automation

By Ernie Crawford, President & CEO, Crawford Technologies

The groundbreaking Medicare Advantage and Part D Final Rule for Calendar Year 2024, published by the Centers for Medicare & Medicaid Services (CMS) in April 2023 significantly expanded the requirements for Medicare Advantage and Part D plans. The ruling, which went into effect on October 1, 2023, just six months after it was published, required health plans to ensure that customer communications related to Medicare and Medicaid plan enrollment and maintenance are made available in accessible formats to individuals with disabilities and those with limited English proficiency. Health plans and their print service providers (PSPs) began scrambling to implement the automation and workflows necessary to make this significant change, especially with the annual enrollment period beginning shortly after the effective date, on October 15. PSPs that handle healthcare documents for their enterprise clients face several challenges in meeting the requirements of this mandate within such a short timeframe.

There was also concern that not meeting these requirements had significant ramifications for future funding that could be gained via the CMS STARS program, a ratings system that allows Medicare consumers to compare the quality of Medicare health and drug plans being offered. CMS STARS allows consumers to rate plans on customer service, member complaints and experience, problems getting services, drug pricing and patient safety. Plans that garner high ratings (4 stars and above) receive financial bonuses from CMS, which can be used to enhance plan benefits. Conversely, plans with consistently low ratings (below 3 stars) can face penalties, including potential removal from the Medicare program.

Understanding Document Accessibility Requirements

Document accessibility involves providing accommodations to print/mail and digital documents that allow access to content. This means having the ability to offer inclusive documents to individuals that are blind, partially sighted, have cognitive disabilities or have limited English proficiency. To meet these individuals’ needs, PSPs must produce the required healthcare documents in a variety of accessible formats that include braille, large print, e-Text or audio formats made available online or produced on a CD.

The need for establishing proper security is also in the mix of necessary requirements. Since healthcare documents contain sensitive patient information protected under the Health Insurance Portability and Accountability Act (HIPAA), the accessible formats must maintain the same level of privacy and security as standard formats. This includes securely managing braille or large print versions of documents, which may require specialized handling and storage processes.

Making a Game Plan

Because the CMS rule was introduced so close to the annual enrollment period for Medicare, PSPs with healthcare clients were pressed for time if they needed to update their processes and technology. What traditionally were small requests that amounted to a few hundred pages for accommodation suddenly mushroomed into millions of pages of health enrollment and member documents with alternate formats requiring digital and physical accessibility. In addition, translation into member languages for the top 5% of populations in each geographical area was required. Developing complex healthcare communications in additional languages loomed as one more time-consuming and resource-intensive process.

While challenging, the CMS accessibility mandate pushed forward-thinking PSPs into creating a game plan for investing in solutions to expand their core competencies. To meet CMS’ new requirements would require replacing cumbersome, slow, manual processes with an automated solution that gave them the ability to meet the document accessibility needs of organizations of all sizes.

What to Look for

Choosing to automate the document accessibility process would enable an organization to make documents accessible in seconds instead of days or weeks. Another significant advantage of automation is the ability to receive PDFs built from multiple systems and make a document accessible on the fly. Having this capability can significantly reduce document archiving costs, which, in some instances, can be more than 30 times higher when stored in accessible formats.

Additionally, an automated approach can be easily modified to support evolving industry standards, as templates or rules can be updated to support the new versions. On the other hand, if documents were created or stored using older guidelines, they all may have to be updated individually to support the new standard, which can be cost prohibitive.

There are many tools and resources available to aid organizations in delivering accessible documents. Selecting the appropriate solution hinges on understanding the essential features required. Here are some fundamental requirements:

· Ensure the solution supports various accessible formats, including print/mail, digital and alternate formats.

· Consider future needs and document volume, delivering scalability.

· Confirm that the solution integrates with existing workflows and document management systems to minimize disruption.

· Consider a solution which provides automatic accessibility validation to ensure compliance.

· Verify compliance with digital accessibility standards such as WCAG, PDF/UA and/or Health and Human Services (HHS).

· Consider a single, robust solution capable of delivering all your document accessibility needs, rather than numerous point solutions.

· As language regulations evolve (as with the recent CMS Final Rule), seek a solution that delivers document accessibility alongside automated language translations.

While an initial investment in a solution is necessary, once automation systems are in place, a company can look forward to a significant reduction in long-term labor costs associated with manual remediation of documents, greater accuracy and meeting accessibility requirements more cost-effectively.

Ultimately, It’s Just Good Business

Having the ability to produce accessible documents goes beyond increased efficiency, easier management of large mailing volumes and adherence to standard regulations. The paramount goal is to ensure documents not only are compliant but are also usable, facilitating easy navigation and information absorption for customers and employees. Accessible documents are vital for creating a truly inclusive society. Prioritizing accessibility as a business ensures that everyone, regardless of ability, has equal access to critical information, ultimately driving engagement and trust. Achieving accessibility is about fostering inclusivity and breaking down communication barriers for an exceptional customer experience for all.

A digital document industry pioneer, Ernie Crawford is President/CEO and founder of Crawford Technologies. One of only a small number of people worldwide with M-EDP (Master Electronic Document Professional) designation, Ernie has more than 30 years of senior marketing and management experience in the high-volume digital printing market.