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If I change Medicare Advantage plans during the year, will the amount that I have already spent out-of-pocket for Medicare Part A and Part B coverage transfer to the MOOP of my new plan?


Maybe.  If you are able to change or transfer to another Medicare Advantage plan offered by the same insurance company (or plan provider, such as Humana or United HealthCare) during the plan year, you will be able to transfer the amount that you have personally spent for your Medicare Part A and Medicare Part B coverage toward your new plan's Maximum Out-of-Pocket (MOOP) limit - but this is only true if your new Medicare Advantage plan is offered by the same insurance carrier or Medicare plan sponsor and you are moving into the same type of Medicare Advantage plan (for example, HMO to HMO or PPO to PPO).

As noted by Medicare:

"During a contract year, when an enrollee switches to another [Medicare Advantage] plan of the same type (for example, from one HMO to another HMO) offered by the plan, his/her accumulated annual contribution toward the annual MOOP limit in the previous plan to date is to be counted towards his/her MOOP limit in the new MA plan. As applicable, this transfer of MOOP applies to both in-network and out-of-network MOOP."

However, Medicare does provide some flexibility so companies can allow your MOOP to transfer between Medicare Advantage plans even when the plans are not similar (for example, you were in an Aetna HMO and join an Aetna PPO).  The Medicare Advantage plan manual continues on to note:

"Additionally, MA [Medicare Advantage] plans may extend the transferability of the enrollee’s contribution toward his/her annual MOOP so that it applies to an enrollee’s transfer during the contract year to any MA plan type offered by the MAO.  For example, if an enrollee makes a mid-year change to move from an HMO to a PPO offered by the same MAO [Medicare Advantage Organization], his/her current contribution toward the MOOP limit may follow the enrollee and be counted towards the MOOP limit in the PPO.  This allows those enrollees who are eligible to make mid-year plan changes to freely select among the diverse MA plan options offered by an MAO [Medicare Advantage Organization]."

(source: Medicare Managed Care Manual Chapter 4 -Benefits and Beneficiary Protections, Section 50.1 – Guidance on Acceptable Cost-sharing (Rev. 121, Issued: 04-22-16, Effective: 04-22-16, Implementation: 04-22-16) (approximate page 53) (emphasis added) (https://www.cms.gov/ Regulations-and-Guidance/ Guidance/Manuals/ downloads/mc86c04.pdf)


And a small amount of background:


The issue of transferring your MOOP between Medicare Advantage plans was introduced in the Centers for Medicare and Medicaid Services (CMS) 2015 draft Call Letter:

Part C Policy Updates

B. Transferability of MOOP Contributions When an Enrollee Changes Plans During the Contract Year

"According to current guidance, when an MAO enrollee switches to another plan of the same type offered by the MA organization under the same contract, his/her accumulated annual contribution toward the annual MOOP limit in the previous plan to date is counted towards his/her MOOP limit in the new MA plan. We believe it is reasonable to further extend the transferability of the enrollee’s contribution toward his/her annual MOOP to any MA plan type offered by the same MAO. Thus, if an enrollee makes a mid-year change from an HMO to a PPO offered by the same MAO, his/her current contribution toward the MOOP limit should follow the enrollee and be counted towards the MOOP limit in the new MA plan. This allows those enrollees who are eligible to make mid-year plan changes to freely select among the diverse MA plan options offered by an MAO. We note this guidance is also applicable to employer group waiver plans (EGWPs)." (page 109) [emphasis added]

(Advance Notice of Methodological Changes for Calendar Year (CY) 2015 for Medicare Advantage (MA) Capitation Rates, Part C and Part D Payment Policies and 2015 Call Letter (February 21, 2014))


And then this policy was finalized in the April 2014 CMS Final Call Letter (with a mention of the feedback CMS received from Medicare Advantage plan providers):

"B. Transferability of MOOP Contributions When an Enrollee Changes Plans During the Contract Year

In the draft Call Letter [noted above], [CMS] proposed that MAOs provide for the transfer of enrollees’ out-of- pocket spending [MOOP] so that it would apply when enrollees disenroll from one plan and enroll in a different plan type offered by the same MAO. Thus, if an enrollee makes a mid-year change from an HMO to a PPO offered by the same MAO, his/her accumulated out-of-pocket spending so far in the contract year should follow the enrollee and be counted towards the MOOP limit in the new MA plan. This was to allow those enrollees who are eligible to make mid-year plan changes to freely select among the diverse MA plan options offered by an MAO.

In their comments on our proposal, some MAOs said that transfer of the enrollees’ out-of-pocket spending across plan types is very complicated because the benefits, cost sharing and deductible requirements are more variable across plan types than across plans of the same type. We are sensitive to the commenters’ concerns but believe that this is an important beneficiary protection and there finalize this guidance as proposed." (page 95)

(Announcement of Calendar Year (CY) 2015 Medicare Advantage Capitation Rates and Medicare Advantage and Part D Payment Policies and Final Call Letter (April 7, 2014))


To learn more about Special Enrollment Periods, you can click here: https://Q1FAQ.com/561.html  or you may wish to contact a Medicare representative at 1-800-633-4227.





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