CA

Blue Shield of California (Blue Shield) appreciates the opportunity to comment on the interim final rule affecting the Medicare Advantage and Part D programs, “Medicare Program; Revisions to the Medicare Advantage and Prescription Drug Benefit Programs: Clarification of Compensation Plans,” as published in the Federal Register on November 14, 2008 (73 Fed. Reg. 67406). Blue Shield recently received clarification from CMS Region IX that the enrollment effective date begins the first year of the six year compensation cycle for brokers and agents. If a member enrolls mid-year, the anniversary of the effective date is the date that plans and CMS must track to pay out renewals. We find that this approach will be administratively challenging to both CMS and Health Plans, especially for the multiple plan changes that occur during the Open Enrollment Period (first 60 days of the calendar year). We propose that the six year compensation cycle be based on the calendar year and that enrollment changes that occur mid-year be pro-rated for the months the member is effective, as long as the enrollee remains in the plan more than three months.