Appendixes
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Additional Commentary Regarding Choice Facilitating Organizations
One committee member raised some additional concerns about the committee's recommendations on Choice Facilitating Organizations and wanted the following comments to be included in this report.
I can see many advantages to organizations that will assist beneficiaries with making informed choices by evaluating, prescreening, and selecting plans that the organization's members might choose.
However, I am concerned about a number of potential problems with these organizations. First these organizations could segment the Medicare market by including in their membership younger and healthier Medicare beneficiaries and steering those members to selected plans.
Second, no standards exist for these organizations. What are they and who will they represent? How will they be funded: by their membership? by the managed care plans (who will provide them an enrollment fee for all members signed up through the organization)? Without some standards for the types of entities that can become Choice Facilitating Organizations, we could see a new type of fraud perpetrated on Medicare beneficiaries.
Third, what standards will these organizations use to select plans. What is to stop a Choice Facilitating Organization from selecting the poorest quality plans because they provide the highest payment for enrollment of members?
Fourth, these plans may well add a new layer of marketing on top of the massive marketing of plans to Medicare beneficiaries occurring in a number of communities. Medicare beneficiaries may be tempted to join a Choice Facilitating Organization because of sophisticated marketing techniques, not because they have carefully selected plans.
For these reasons, I think extra caution is in order. Perhaps HCFA could establish a demonstration project to assess the effectiveness of Choice Facilitating Organizations. At a minimum, some standards should be established for these organizations.