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A Review of the GAO’s Investigation of MEDICARE PART D Prescription Drug Plan

Sponsor Call Center Accuracy and Completeness Assessment

Published: August 9, 2006

Inaccurate or misleading benefit information could cause seniors to choose a prescription drug plan that does not meet their needs or costs more than they should pay.

The Problem: Two-Thirds of the Call Center Responses Were NOT Accurate and Complete!
Senior citizens cannot count on substantive information provided by a private insurer’s call centers for making decisions on which plan is best for them. (See: Kevin Freking, Associated Press, "Callers get shoddy advice on drug plans," The Tennessean, July 11, 2006, p. 1A, 7A.) A GAO (the Government Accountability Office, formerly the Government Accounting Office) investigation found two-thirds (66%) of an insurer’s prescription drug plan (PDP) call centers’ responses to investigators’ questions were not accurate and complete. This is a serious problem for senior citizens. Inaccurate or misleading benefit information could lead beneficiaries to choose a prescription drug plan that does not meet their needs or costs them more than they should pay.

No one should be surprised by this. The Medicare Part D Prescription Drug Plan program was flawed in its plan and overly complex in its execution. With seventy-nine sponsors, largely commercial insurers offering 1,400 standalone prescription drug plans and Medicare beneficiaries typically having a choice of from 40 to 50 PDPs, the complexity is overwhelming.

But what is most disheartening about this is the response to the survey by Mark McClellan of the Centers for Medicare and Medicaid Services (CMS). Rather than seeing this as an identification of a broken process that needs to be fixed, he criticized the GAO analysis as based on inaccurate, incomplete and subjective methods. Instead of looking for ways to improve, Dr. McClellan sought to “defend” the PDP call centers saying that Medicare has never required the call centers to provide detailed information about the prices of specific combinations of drugs [that constituted two of GAO’s five questions]. McClellan cited an internally conducted survey of customer satisfaction, in which he declared callers were 87% “satisfied with their experience.” However, “satisfied” meant the subjects replied with an “agree strongly” or “agree somewhat” to seven questions such as “CSR was helpful” and “CSR was knowledgeable.” (See accessible text file for GAO report number GAO-06-654, "Appendix III: Comments from the Centers for Medicare & Medicaid Services.") None of the seven questions asked would have been able to answer the question whether the information provided was accurate and complete. The callers would not necessarily be able to determine if the information was complete, let alone accurate.

I have reviewed the GAO’s report and have found its investigation to be of sound methodology, with questions carefully researched and designed to verify the accuracy and completeness of the kind of information that seniors need to make wise decisions. The GAO’s questions were developed using the frequently asked questions (FAQs) on CMS’s Medicare.gov Web site and materials from policy analysts that identified information critical to making a choice among the various plans. GAO developed criteria for accurate and complete responses for the questions using CMS’s PDP finder tool on Medicare.gov and information CMS has approved for use by its 1-800-MEDICARE CSRs. Furthermore, CMS officials stated that the planned questions should be able to be answered by the CSRs in the PDP call centers (see back of cover page in GAO report).

The Real Question That Should Be Addressed
What Dr. McClellan should be asking is, “How can we improve the process to provide more accurate and complete information that seniors need to make the right decision about a drug plan?”

There is help. The International Association for Information and Data Quality (IAIDQ) is an independent, not-for-profit organization of individuals and professionals around the world who are learning and applying proven principles, processes and techniques to improve processes to prevent information problems. Whether private sector (the insurers with their call centers) or the public sector (Centers for Medicare and Medicaid Services, anyone can learn how to measure accuracy, analyze root cause of information quality problems and define process improvements to eliminate or minimize information quality problems as uncovered by this GAO assessment.

Basic quality principles for call centers:

1. The sponsors should study the GAO report from a perspective that it seeks to help them improve their call center quality by identifying some real problems in the quality of the responses.
   
   
2. The sponsors – and CMS – should conduct root-cause analysis to uncover the root cause(s) of the inaccurate and incomplete responses. Then, and only then, should they define improvements to increase the accuracy and completeness of the call centers.
   
   
3. Understand clearly what the callers – the information customers – need to know, not just what is easy to provide. Seniors need to know the extended costs of their medications to understand which plan is the most cost-effective for them. This is what the GAO sought to discover.
   
   
4. Develop scripts and calculators that enable the CSRs to answer seniors’ questions in ways that meet their real needs.

Our seniors helped build a strong nation. I hope this can be used to enable our government help our seniors to build a strong and secure retirement.

Author’s Note: The IAIDQ’s mission: “The IAIDQ is advancing information and data quality around the world by building a community, supporting learning and sharing knowledge for the benefit of all information consumers.” The IAIDQ organizes the upcoming Information Quality Conference to be held in San Francisco, October 16-19, 2006, providing presentations and tutorials on critical information quality management methods and techniques. For more information, visit http://www.iaidq.org/.