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.

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