Managing mandated communications like the Annual Notice of Change (ANOC) and Evidence of Coverage (EOC) is increasingly complex. With evolving regulations, shifting member expectations, increased accessibility requirements, and tighter deadlines, health plans face pressure from all sides. Choosing the right partner and solution can help you streamline workflows, reduce errors, and stay compliant.
Whether you are outsourcing your entire process or just parts of it, using these best practices can help. They will reduce the risks of missed deadlines, compliance issues, and member confusion.
TIP 1: Leverage external Medicare communications experts
The Medicare communication landscape constantly changes with CMS model documents, regulatory memos, Member Helpline expectations, and accessibility obligations all evolving. Choosing a vendor that provides technology is important. They should also have health insurance and compliance experts on their team.
These experts should:
- Monitor and interpret model document changes and CMS guidance
- Consult on plan-design and document-content (ANOC/EOC) implications
- Act as an extension of your internal team so that you’re not overly reliant on a single internal SME.
Recent CMS update: For the year 2025, CMS released new model EOC and ANOC materials for Part D in Spring 2024. These updates include the Medicare Prescription Payment Plan. (Centers for Medicare & Medicaid Services)
Toppan Merrill is already accounting for these updates (and any errata) in their templates, review engine and production process.
TIP 2: Maintain a content repository
One of the biggest problems is rewriting content every year. Instead, you should use what you already know.
A robust content repository should include:
- CMS standardized model documents (ANOC/EOC/SB) and any errata updates
- Your plan’s benefit designs, business rules, cost-shares, service-area tables
- Internal “boilerplate” content, supplemental benefit explanations, disclaimers
- Translation/alternative-format assets (see TIP 4)
This foundation allows automation tools to “pull” the correct elements, apply business rules, and assemble compliant documents.
CMS now gives more guidance more often. This includes updates for insulin and vaccines. Having your repository ready lets you respond quickly.
Tip for your team: Update your repository every year before your production cycle starts. This way, last-minute changes won’t disrupt your timeline.
TIP 3: Automate, automate, automate
Manual document assembly is a major source of error: version mismatches, incorrect benefit tables, missing disclaimers, and late deliveries. Automation matters.
The right solution should:
- Use data from your content repository + HPMS (or other plan data) + member-specific data to drive content dynamically.
- Support complex, data-driven templates which assemble ANOC/EOC/SB with minimal manual intervention.
- Provide audit-trail, change-control, versioning, and previewing of aggregated output
From a regulatory standpoint, automation helps you hit key deadlines (see CMS guidance below) and reduces compliance risk.
Recent CMS update: CMS’s final guidance for Part D (Spring 2024) highlighted the timeline for model EOC/ANOC documents for CY2025. (Centers for Medicare & Medicaid Services)
Automation also helps you react to mid-year errata or regulatory changes (e.g., insulin or vaccine coverage language) quickly.
Recommendation: Before each AEP cycle, create your automation run-book. Check the templates and test the output. Have a backup plan ready for any last-minute data changes.
TIP 4: Integrate accessibility and alternate formats from the start
Accessibility and language inclusivity are no longer optional; they’re required. A recent blog shows that members have specific needs. They want materials in Braille, large print, and audio formats.
Regulators also require 508-accessible PDFs. Additionally, translations into key languages are necessary. (Toppan Merrill)
Key requirements and considerations:
- Materials must be offered in alternate formats (Braille, large print 18pt+, audio) when requested.
- Translations: CMS defines “threshold languages” by the number of members in the service area. Documents must include non-discrimination taglines in up to 15 languages.
- Digital documents must follow Section 508, WCAG 2.0 AA, and PDF/UA standards. This helps screen readers and assistive technology navigate them.
Why this matters for ANOC and EOC workflows:
- Your production flow should include different delivery formats. These can be print, email, portal, or even Braille/audio. This should not be an afterthought.
- You need data on member preferences (language, format) captured upstream.
- Your repository/templates must support substitutions/translations.
- Your proofing process needs to include accessibility review (not just content proofing).
CMS is doing more audits on accessibility and member communications. Adding accessibility to your ANOC/EOC cycle is a good way to stay compliant.
TIP 5: Simplify your proofing and approval workflow
Delayed or error-filled document proofs are a recurring pain point. Toppan Merrill advises that document proofing and approval tools should:
- Let multiple reviewers’ markup/comment directly on the document (not via disparate Word/Excel docs or email threads)
- Provide transparent version control: who saw what, when, what changes were accepted, etc.
- Enable audit-ready reporting: proofing-history, signoffs, exceptions logged.
From a regulatory perspective, if your ANOC/EOC is late or contains incorrect information, you might miss deadlines. This could also affect how you notify members.
The organization must provide materials to enrollees by September 30. This is for the ANOC in regular Medicare Advantage and Part D schedules. (CMS) Therefore, the proofing process must align with production workflows and downstream distribution.
Tip: Set up a “proof to production” handoff process. This should include automated checks. For example, make sure benefit table numbers match the repository.
Check that the translation status is complete. Also, flag the accessibility format. This will help eliminate manual revalidation with every run.
Bonus: Don’t wait until the last minute
Many ways exist to use technology and best practices. These can help improve efficiency, member understanding, and engagement for the next Annual Enrollment Period (AEP). But if you wait until the pre-marketing rush you invariably incur risk, overtime costs, and stress.
Check out our blog on omnichannel member communications. It discusses planning early and updating your member communications program now instead of waiting.
In the current regulatory environment, “early” means starting months before you build your documents. You should update your repository, validate templates, test automation workflows, check for accessibility, and have a proofing workflow ready.
How Toppan Merrill can help
Toppan Merrill offers a full suite of services supporting document creation and management, sales enablement, omnichannel communications, print/digital production, and more. Health plans can respond quickly to changes in regulations, member needs and markets.
Toppan Merrill delivers:
- CMS-model-compliant templates for ANOC/EOC with formatting accuracy and proven delivery systems.
- Data-mapping, e-delivery, bounce-to-print options, chain-of-custody production, real-time analytics.
- Integrated accessibility/alternate-format (508/ADA) support.
Learn more about our health-plan member communication solutions.
Conclusion
By using smart technology and expert help, you can reduce problems and risks. A strong content base and automation will also help. Built-in accessibility and easy proofing will make the process smoother. This will lower the last-minute rush related to your ANOC and EOC cycle.
Given the pace of change from CMS and member expectations, the time to act is now, not when the deadline looms.
