The Centers for Medicare & Medicaid Services (CMS) timeliness monitoring is currently underway at organizations with active contracts in 2017 and 2018, with a few exclusions, such as Medicare-Medicaid Plans and organizations that underwent a program audit in 2017 and did not have any invalid data submissions in key audit areas. Is your organization excluded? See the Health Plan Management System memo dated December 12, 2017. If I had a nickel for every time someone referred to this activity as a timeliness audit, I’d have quite a pile of nickels. While it is not an audit, it sure feels like one as the validation activity is the same.
The first of three waves of letters is being issued this month. After upload, a data review will be conducted and a validation webinar scheduled. Once complete, timeliness rates will be calculated. To make sure this is an efficient process, here are some ways we have recently assisted clients:
- Coach and guide delegates in the timeliness monitoring requirements
- Evaluate universes for adherence to instructions
- Review both timely and untimely case samples for data accuracy
- Review systems to validate accurate population of fields
Data integrity continues to be a priority not only for informing Star Ratings and Independent Review Entity data accuracy but also for required Part C and Part D reporting and for the compliant operations of plan administration. Universe preparation steps are not one size fits all, as the methodologies for a small plan delegating very few activities and the steps a larger, more delegated model plan takes will vary. Not surprisingly, during the course of our review, our team often finds potential issues or concerns unrelated to timeliness. This gives our client partners the opportunity to conduct a deeper review to address and mitigate.
We currently provide guidance, suggestions, and best practices for universe development to address quality and identify potential risks. If your organization is not getting these data universes correct, you should ask yourself, what other reports might be flawed? Dashboard metrics? Board reporting? Identify and correct these issues before CMS and their contractors find them for you.
Registration is now open for the Gorman Health Group 2018 Forum, April 25-26, 2018, at the Red Rock Resort ideally located near the Red Rock Canyon in Las Vegas.
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