In 2017, the Centers for Medicare & Medicaid Services (CMS) moved from a Readiness Attestation to a Readiness Checklist with a Strategic Discussion with your Regional Office. A movement away from attestations may move some plans to take the process less seriously. CMS raises issues in the Readiness Checklist because they are either critical components or because they are areas of risk. It isn’t often in life we are handed a list we can use to double-check critical components are in place.
What processes should you put in place post Readiness Attestation? Whether it is coordinated by Compliance or completed within an operational unit, here are five actions to make the most of the Readiness Checklist:
- Identify Departments Involved in the Function. Some functions are completed/contained within one functional area. Other functions typically cross lines into more than one functional area such as Medicare Secondary Payer (MSP), which typically involves Enrollment, Reconciliation, and Claims. Mapping out all areas that touch a function to ensure there are no dropped requirements will involve all areas and allow the plan to accurately validate compliance.
- Distribute the Readiness Review to All Involved Staff. Sometimes health plans want to spare staff from reviewing original Health Plan Management System (HPMS) memos as they are lengthy and, at times, confusing. Letting staff review memos can often impart a different awareness and seriousness. Providing a summary along with the memo and presenting relevant information in a team meeting can reinforce CMS’ seriousness but also highlight the critical points for that team.
- Review Policies and Procedures (P&Ps) for Compliance. You may have an annual review process that doesn’t coincide with the release of the Readiness Checklist. It is still important you verify your P&Ps are not contradictory to anything outlined in the Readiness Checklist. Completing that extra review can ensure compliance with CMS processes which may have been missed during routine updates.
- Maintain Evidence of Compliance. It is easy to indicate you are compliant with a function, but compiling evidence of compliance results in a higher level of diligence, one management or Compliance can review. Health plans may not need to attest to CMS they are in compliance, but that doesn’t mean health plans should not be able to demonstrate that compliance.
- Mitigate Deficiencies. There is no doubt about it – the Readiness Checklist comes out during a very busy time of year. Sometimes the chaos that surrounds the Annual Election Period (AEP) requirements can result in a failure to put mitigations in place for issues identified in the Readiness Checklist review. This oversight puts the plan at risk, particularly since CMS called out the items as critical components. Make sure your health plan establishes resources to focus on any needed mitigations to bring your plan into compliance.
Without that formal attestation process, don’t devalue the Readiness Checklist and required actions. Put a plan in place today to coordinate review, validation, and mitigation activity. Good prior planning can ensure the Readiness Checklist can be a valuable tool to make certain your program is ready for 2018.
Our consultants have implemented items from the 2018 Readiness Checklist for health plans just like yours. If you need assistance verifying you are ready for 2018 or have questions on your processes, we can help. You can reach us through our website or by emailing me directly at email@example.com.
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