Healthcare Tech Fails to Meet M3P Needs

June 6, 2024

Enrollment for the Medicare Prescription Payment Plan (M3P or MPPP) is right around the corner. In October, Medicare Prescription Drug Plans (PDPs) and Medicare Advantage (MA) Plans will have to be able to enroll members into their M3P program. Starting January 1, 2025, these same plans will need a system in place to spread member out-of-pocket costs over the plan year. Suddenly, plans will be offering financial services in addition to medical benefits. Current healthcare technology is not equipped to support financial services. 

Using traditional healthcare solutions to support M3P is equivalent to forcing a round peg into a square hole. Health plans will need to drastically transform their infrastructure to comply with M3P’s demands. Adapting current technology will mean significant time and investment, but plans can avoid this entirely by using existing financial technology solutions to operate their M3P programs.

Operational Requirements

M3P is not a traditional Medicare benefit, but it can still affect a plan’s STAR ratings. M3P will likely confuse many beneficiaries, so plans must be ready to augment their customer service operations. Confusion could lead to declining member experience, directly impacting a plan’s STAR rating. Health plan customer service representatives are not equipped to deal with the financial side of M3P. Most members are familiar and comfortable with the current credit card/installment loan experience, and using a similar approach for M3P will ensure a smooth transition. Minimizing the potential for bad member experiences is absolutely crucial to maintaining a favorable STAR rating.

Financial technology vendors have the knowledge to explain M3P to eligible beneficiaries, highlight the program's benefits, and provide essential details on how the program works. Why go through the headache of trying to adapt existing solutions for something they were never designed to handle?

Technology Requirements

M3P payment calculations are not straightforward. They require taking into consideration multiple variables, including the date a member enrolled, remaining periods in the year, and the maximum monthly cap, which can change from month to month. Systems must also process transactions in near real-time, updating member balances to reflect transactions as they occur. Health plan technology is not up to this task. Plans need systems akin to those used by financial services firms.

Health plans need to confront the reality that their current technology was not designed to perform financial service transactions. Augmenting systems to meet M3P guidelines will be capital and time-intensive, and time is running out.

Compliance Requirements

Plans know they must comply with CMS’ M3P requirements. CMS has set out guidelines for enrollment, communication with beneficiaries, processing payments, and reporting. What plans are not expecting is the need to also comply with the exhaustive list of federal banking, state banking, and payment regulations:

  • The Electronic Funds Transfer Act (Reg E) protects consumers who use electronic payment methods (debit cards, ACH transfers, etc.) to make M3P payments. Plans will need to ensure proper authorization, disclosure of fees, and error resolution.
  • The Truth in Lending Act (TILA) requires clear and accurate disclosure of credit terms, including finance charges and APRs. M3P payments will likely be interest-free, but TILA sets out specific transparency requirements that plans must comply with.
  • The Gramm-Leach-Bliley Act (GLB) safeguards consumer financial information. Plans will need secure systems for taking and storing payment information.
  • The Payment Card Industry Data Security Standard (PCI) regulates security standards for credit card payments.
  • The National Automated Clearing House Association (NACHA) operating rules govern the network used for electronic fund transfers.
  • The Fair Debt Collection Practices Act (FDCPA) protects consumers from abusive debt collection practices. Plans may need to collect overdue payments, and they’ll have to ensure they comply with FDCPA while doing so.

The list goes on. Without consulting finance and banking regulation experts, plans won’t be sure their systems and processes are compliant, and could be subject to fines and/or legal action on behalf of beneficiaries. Even if they do hire the appropriate experts, their current systems won’t have the relevant controls, policies, and procedures built into them.  

Investment

If plans opt to stick with their existing technology, they’ll need to make substantial changes. A few small tweaks simply won’t cover the unwieldy obligations that M3P has suddenly thrust upon plans. Even if plans have already embarked down this path, time is running out. If developers can’t meet their deadlines, and they often don’t, plans will be in an awful position come October and an even worse position in January.

Buy now, pay later solutions are a low-cost alternative that does not require custom coding. They can be deployed quickly, providing everything a plan needs to administer M3P payment plans. Most financial technology solutions have flexible pricing models to accommodate a plan’s objectives and budget.

Buy Now, Pay Later

Instead of attempting to adapt the current infrastructure to the many challenges M3P presents (forcing a round peg into a square hole), why not launch and operate the M3P with something already set up to do the job? Buy now, pay later solutions use infrastructure tried and tested by financial service companies. They can receive transactions, update ledgers in real-time, and accommodate the many M3P repayment scenarios that will differ from beneficiary to beneficiary.

They have built-in customer service, allowing beneficiaries to reach expert representatives in various ways, including phone, email, and live chat. Beneficiaries will have everything they need to make informed decisions about M3P, ensuring a smooth member experience.

Buy now, pay later solutions have entire infrastructures designed to comply with banking and payment regulations. They were built in consultation with experts in financial compliance requirements.

Deploying a buy now, pay later solution means foregoing a significant investment in the people, processes, and technology plans needed to operate M3P efficiently. Beneficiaries can be enrolled and supported in weeks rather than months.