The 2019 Application – Key Dates

As a follow up to my last article on the Notice of Intent to Apply, I give you an enhanced chart of 2019 application activities outlining things you should have been doing or should be in the middle of now. Thanks to the Centers for Medicare & Medicaid Services (CMS) for creating a base, published recently via memo – my colorful additions peppered throughout for your perusal. If past activities have not been done yet, it is time to get a move on, or you risk missing the deadline.

Calendar Year 2019 Application Activity Date
Determine the feasibility of applying for a new plan or expanding an existing plan; identify vendor partners to contract with who will support administrative or health services, begin contracting process or review existing contracts to ensure application requirements will be met Ongoing process
Review past finalized application guidance, determine licensure needs, contact pertinent state(s) to establish their needs and timeline June 1, 2017
Review the 60-day release outlining the proposed changes to the 2019 applications August 1, 2017
Tell Provider Contracting not to rest on their laurels August 2, 2017
Comments due on the 60-day release of the applications October 2, 2017
Read CMS’ Notice of Intent to Apply (NOIA) memo dated October 13, realize there are 36 calendar days between the release of the final application and submission, suppress panic October 13, 2017
Read this chart, and if anything is making you twitch, let me know October 16. 2017
Create a draft project plan, assigning specific tasks to your application project team; establish an earlier submission date; field angry emails from the team but hold firm; obtain the team’s vacation schedules now through submission date, establish back-ups October 30, 2017
Review the 30-day release of the draft 2019 applications (approximate time) November 10, 2017
NOIA deadline to ensure access to the CMS Health Plan Management System (HPMS) November 13, 2017
New applicants should download the CMS User ID connectivity form (aka CMS Access Request Form) and distribute to the application submission team and C-suite team members who will need to complete attestations. Provide specific instructions on filling out the application, or don’t, if you like a lot of re-work. Ensure back-ups. Send originals via traceable carrier to CMS. November 15, 2017
CMS sends NOIA confirmation e-mails to entities meeting the November 13 NOIA deadline to ensure timely HPMS access November 30, 2017
CMS User ID connectivity form submissions must be received by this date to ensure user access to HPMS by January 9, 2018 December 1, 2017
Try to enjoy the holidays, because that application work is coming January 1, 2018
Calendar Year 2019 Medicare Advantage (MA), Part D, and Medicare-Medicaid Plan (MMP) applications posted on CMS website January 9, 2018
Finalize project plan based on the final guidance, adding any new tasks and team members required; register for CMS user calls; re-communicate internally established submission date January 9, 2018
Final day to submit NOIA for 2019 January 26, 2018
If you believe stragglers will cause you to be working up to CMS’ deadline, order flowers for your significant other so Valentine’s Day isn’t completely ruined February 12, 2018
CY 2019 MA, Part D, and MMP applications submission deadline February 14, 2018




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Regan Pennypacker
Regan Pennypacker

Regan is Senior Vice President of Compliance Solutions at Gorman Health Group (GHG). She leads the Compliance Solutions practice, responsible for multidisciplinary projects such as Part C and Part D audits, new applications, marketing material reviews, risk assessments, and training engagements. As a member of this team, she has provided compliance direction and insight on industry best practices to many GHG clients. Regan brings GHG clients 19 years of experience in the healthcare industry. Read more

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