Medicare Advantage (MA) Plans face a significant shift in rules around member communications starting in 2025. Based on the 2025 MA and Part D final rule, plans are now tasked with honoring member requests for alternate formats of communication immediately and in perpetuity following the first request.
MA plans need to take a proactive and comprehensive approach to recognizing member preferences around language and format.
Starting with these crucial steps:
1. Find opportunities to capture preferences across enrollee touchpoints.
MA plans should map out and thoroughly examine every interaction point that a member has with the plan — from initial enrollment and welcome kits to routing correspondence, Explanation of Benefits (EOBs), website interactions, call center communications, and even in-person meetings. Look for opportunities to clearly and consistently capture both language and preferred communication format preferences at each of these points. This may look like digital forms on digital channels, phone scripts, or questions in enrollment materials.
2. Create a centralized preference management system.
It’s essential that all of your member communication systems have the ability to capture and store member preferences, best practice is to establish a single, central repository for managing and accessing all of those capture preferences. This gives all teams responsible for member communications a single source of truth on member preferences, supporting consistency in how preferences are applied across all communications channels and systems. This central management also simplifies updates to those preferences. Instead of manually going in to synchronize preferences across each system, updates can be made in one place, reducing the risk of errors and inconsistencies.
3. Assess plan operations to identify gaps.
Conduct a complete audit of your current operational processes to identify any weaknesses or gaps that might hinder your ability to provide communications in alternate languages and formats. This includes evaluating translation workflows, document generation systems, mailing processes for non-standard formats (like Braille or large print), and internal communication channels for managing member preferences.
4. Validate system functionality and software applications.
Ensure that all your relevant technology systems and software applications are able to accurately and reliably track and manage enrollee language and format preferences. This means these systems and apps should be able to record stated preferences and make those preferences easily accessible across different functional areas (like member services, claims processing, marketing, etc.). Moreover, technologies should be able to integrate preferences into communication generation processes, mitigating the risk of errors or oversights.
5. Review all plan correspondence with enrollees.
Analyze all types of communications sent to your members to confirm your plan’s ability to produce those communications accurately and efficiently across all alternative languages and formats. This analysis should include standard letters, notices, education materials, and even personalized one-off communications. Critically, make sure you’re assessing the scalability and cost-effectiveness of producing alternative formats across all of these communication types.
6. Update policies, procedures and staff workflows.
Develop, implement, and monitor adherence to documented policies and Standard Operating Procedures (SOPs) for handling enrollee preference requests for translated materials or materials in alternate formats. These policies and SOPs should outline responsibilities, timelines, and specific steps for processing and fulfilling these requests accurately and in a timely fashion. Plans should consider integrating preference verification steps into existing workflows to further validate member preferences.
7. Train all impacted teams and staff.
All relevant personnel involved in the generation or management of member communications should receive comprehensive training — including member services, marketing, enrollment, claims, and even IT teams. This training should ensure they thoroughly understand the new language and format requirements and the direct impact of these new requirements on their daily responsibilities (including any changes or introduction of new policies and SOPs as discussed in the previous step). This training should cover how to consistently and accurately capture preferences, access preference information in various systems and apps, and ensure these preferences are reflected in the communications generated by these respective teams.
8. Educate enrollees on the availability of alternate languages and formats.
Complying with the new requirements shouldn’t be a checkbox exercise — plans should take it as an opportunity to double down on improving member experiences. That means proactively informing members about the availability of translated materials and alternate communication formats through various touchpoints — within routine member communications and newsletters, in website announcements and educational outreach, and even focused advertising campaigns. Make it easy for members to understand their options and how to request their preferred format.
9. Update plan monitoring.
The new regulatory requirements around member communication preferences need to be integrated into your plan’s overall compliance program. This includes establishing monitoring mechanisms to track adherence to member preferences, conducting regular audits of communication processes, and implementing corrective action plans when necessary.
The challenges & risks of decentralized communication teams
Many MA plans operate with communication responsibilities dispersed or siloed across various departments based on the communication’s topic. This decentralized approach makes sense from a specialization and efficiency standpoint, but it creates significant complexity and risk points when implementing new regulations, like those around member communication preferences, that require universal adherence across the organization.
Ensuring consistent understanding and application of the updated communication rules becomes a much greater challenge when ownership of these communications is fragmented. Inadequate staff training and inconsistent implementation can lead to errors in capturing or fulfilling member preferences, resulting in non-compliance and frustrated members.
A foundational strategy: Building a cross-functional communications committee
Establishing a centralized “education team” responsible for disseminating information and ensuring consistent application of these new regulations across all departments and all member communications is crucial. One highly effective approach is to form a dedicated committee with a representative from each team that manages member communications. This cross-functional committee would be responsible for carrying out most of the steps outlined above.
By prioritizing centralized oversight and fostering collaboration through a committee approach, MA Plans can effectively navigate these new regulatory requirements, enhance member experience, and ultimately foster stronger, more trusting relationships with their membership.
How Toppan Merrill can help
At Toppan Merrill, we understand the complexities of member communications. We work with all types of data formats. We understand you’re working with tight SLAs, and we are familiar with having to make a quick update because a model document has changed. We would love to talk to you about our Letter Program. From document creation and management to sales enablement, omnichannel communications, printing services, and more, we deliver best-in-class solutions that help you respond quickly to changes in regulations, member needs, and markets.
