7.   Can a dual eligible beneficiary switch plans each month?  Why would someone want to do this?

These questions raise issues regarding the enrollment of multiple subsets of the Medicare population. The first issue concerns who may switch plans and when:

• Ongoing SEP for Full Duals: Full duals (those with Medicare and full Medicaid) may switch plans at any time (effective the first day of the following month). They have a continuous Special Enrollment Period (SEP).
• Ongoing SEP for Partial Duals: The continuous Special Enrollment Period was later extended to include partial duals-- that is, those enrolled in the Medicare Savings Programs or MSPs (QMB, SLMB, and QI).
• Other Part D enrollees and plan switches: Other low-income beneficiaries who applied and were determined eligible for extra help (as well as the SSI-only population) and whose enrollment is facilitated will have one SEP that extends through the calendar year. This SEP ends when the individual makes one change-- either an enrollment into a new plan or a disenrollment from the plan into which they were facilitated. All other beneficiaries who are not full or partial duals can switch Part D plans during appropriate enrollment periods (see HAP's Chart of Enrollment Periods). To change Part D plans, the beneficiary needs only to enroll in the new Part D plan. This new enrollment will disenroll the individual from the first plan. It is important to remember, however, that any new enrollment into a Part D plan becomes effective on the 1st of the month following the month of enrollment. For example, if a beneficiary submits a new enrollment form on April 24, the new plan will be effective on May 1.

The second issue concerns an individual's reasons for switching plans:

• There are numerous reasons why an individual would decide to change Part D plans. First, many duals were auto enrolled into Part D plans on January 1. Since this process was random, many duals might not have been enrolled into a plan that met all of their drug and/or pharmacy needs. Other reasons why a beneficiary might want to switch plans may be to enroll in a plan with better customer service, to find one with more straightforward exceptions and appeals processes. Finally, the drug needs of many Medicare beneficiaries will undoubtedly change during the plan year. While not all Medicare beneficiaries are entitled to the continuous Special Enrollment Period, the full and partial duals will be able to utilize their continuous SEP to change plans to accommodate their new drug needs during the plan year.

The third issue concerns the eligibility timeframe for switching plans:

• In addition to being aware of the SEPs, it is important to consider at what point during the month to enroll in a new plan. CMS is strongly encouraging people to switch plans prior to the 15th of each month in order to assure enrollment in the new plan on the 1st of the following month. CMS believes that this will allow enough time for Medicare and drug plans to update their systems and mail important information to the new enrollee. CMS has released a fact sheet on this topic. 

Reference Information

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