You hear the “ding” or the common “buzz, buzz, buzz, buzz”; immediately you reach for your mobile device. Maybe it’s a text message asking you to grab something at the store, or a note from a friend on his / her way? We know the impact text messaging has on our day-to-day personal lives. Could we use that same medium to notify our members when we have updated plan information for them?
Short message service (SMS) commonly referred to as text messaging isn’t new; it’s been around since 1992. As ownership of mobile devices grew and the population stayed on the go it has grown to the most popular communication tool (exceeding email and instant messaging). So, if people prefer text messages why are we not using them for health plan messages?
The Centers for Medicaid & Medicare Services (CMS) has long been considering its position regarding text messaging to beneficiaries (which refers to any Medicare-eligible person, enrolled or not). In the 2019 Member Communications and Marketing Guidelines (MCMG), CMS updated section 30.6 to the Electronic Communications Policy which now prohibits text messaging as a form of marketing. CMS further deems texting as form of unsolicited contact (a violation of CMS guidance) with language added to section 40.2. In recent years, CMS began acknowledging other forms of electronic communications and introduced those same prohibitions for emails unless advance permission was granted by the recipient. Now, CMS no longer requires advance permission for emails. The approach was finally modernized and instead requires health plans to include an opt-out function in every email delivered. We’ve come a long way, baby, but what about the onset of texting and its success rate? Can plans take the same path as email, and interpret CMS’ prohibition for texting is actually allowable and not a form of unsolicited contact if permission is granted?
The MCMG doesn’t specifically state a blessing under those conditions, but in the spirit of the guidance it seems the same progression is surfacing for text messaging as with email. Hopefully CMS will find flexibility when facing these facts: With 99% open rates for text messages, sending an email doesn’t hold a candle at 18% according to Text Marketer. Utilizing text to communicate can be extremely effective, but with the prohibitive guidance from CMS when combined with HIPAA compliance and security, organizations can be at huge risk for marketing and privacy violations.
In its current prohibition, CMS has likely considered the possibility of undue costs to plan enrollees who may receive additional charges when text messages roll in, particularly if they’re not informed cell phone users or don’t have a texting package with their carrier. If marketing floodgates are opened for health plan solicitations, and if even member communications were initiated through text messaging, that buzz could result in charges from their mobile carriers members aren’t expecting. It’s possible CMS weighed the fact of so many security options into their texting prohibitions, and consumer awareness for protecting their devices.
On the flip side, utilizing text messaging can have positive effects in promoting wellness, medication compliance and access to updated plan information in ways that can help both the Medicare and Medicaid audiences and the health plans. With the significant open rates, sending a reminder text to schedule a wellness check can help boost scores in Star Ratings measures by supporting a member’s use of preventive services. Or, texts can provide links to the most current provider directory or evidence of coverage ensuring members have same-time access to their provider’s network status (which can change on a dime) and benefits information at their fingertips. Perhaps you’re someone who’s appreciated a text reminder to pick up your prescriptions at a Walgreens or Target pharmacy. Proper use of prescription drugs is another scoreable area contributing to positive Star Ratings. When texting becomes an accepted practice for health plans, even more ground can be covered to nudge member activities that promote wellness and support Star Ratings.
What about member retention? A recent survey conducted by DEFT research shows that members’ knowledge and understanding of Medicare Advantage plans is a critical factor in determining their loyalty, and as a result the survey showed Medicare advantage member satisfaction increased 26% over the last three years. As seen in the DEFT survey, loyalty is driven by member experience, so the more resources insurers provide for members to help them understand their coverage the more likely they are to stay with their current plan.
For example, CMS allowed electronic delivery of EOC’s this year. Just emailing your members a link to the EOC or adding it to your website will only reach 18% of your member base, however, a text message could reach 99%. Member experience doesn’t have to stop there. If CMS eventually confirms guidance for texting members, plans could alert members that their updated EOC is ready for review with a link to an interactive microsite that provides intelligent search. Not only does this approach reach the majority of your members, it provides a superior member experience by making it easy for them to find exactly what they are looking for in their EOC, thereby reducing calls to your call center and providing a quick resource to the knowledge and understanding of their plan – creating loyal members.
What does this mean for health plans?
We’d love to see CMS embrace texting as part of its acceptable electronic communications, even if similar opt-out requirements are applied. Until CMS provides more clarity for the potential of texting with advance permission, plans should probably confirm any outreach campaigns with their trusted contact at CMS.
If implementing a SMS strategy, don’t forget compliance and security. Ensuring you’re compliant with Telephone Consumer Protection Act (TCPA) by receiving consent is critical to your success. Utilize a preference center that can manage delivery preferences at an individual communication level and even down to the delivery method. This will ensure your members are able to choose their preferred delivery method for each of your plan’s communications, letting them choose what they want, how they want it. Security is crucial in a SMS strategy. Plans must utilize and maintain systems/platforms that are secure and minimize the risks to patient privacy and confidentiality as per HIPAA regulations. Sending secure links that require logins or non-PHI/PII information via SMS can help to minimize security risks but if your strategy includes getting personal in your text you need to ensure your information is encrypted. Adding SMS messages into your communication strategies can been extremely beneficial to engagement, but ensure you minimize risks and provide a superior member experience throughout the process. Let Toppan Merrill help you with everything from secure microsites to preference management. Request a demo to see how we can maximize results and create loyal members, so the next “ding” or the “buzz, buzz” is you creating loyal members.