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If you did not have the pleasure of being part of a Centers for Medicare & Medicaid Services (CMS) Program Audit in 2017, don’t be caught off guard if you receive your invitation this year.
The Centers for Medicare & Medicaid Services (CMS) Advance Notice and Call Letter included additional reminders to plans about managing Qualified Medicare Beneficiaries (QMBs). A QMB is a dual-eligible beneficiary who does not have full Medicaid. Instead, that individual has Medicare cost-sharing subsidies by the state Medicaid program for Part A and B covered deductibles and coinsurances. When a QMB member is part of a Medicare Advantage (MA) plan, it becomes the MA plan’s responsibility to ensure providers do not balance bill the member for the plan deductibles and cost sharing for Medicare-covered services provided by the MA plan.
The focus on compliant Independent Review Entity (IRE) data should come as no surprise to Part D sponsors. In December 2016, the Centers for Medicare & Medicaid Services (CMS) released the Health Plan Management System (HPMS) memo, Compliance and Enforcement Actions Related to Part D Auto-Forwards, indicating sponsors with inordinately high auto-forward rates were subject to compliance actions that could be escalated to enforcement actions. The memo established a threshold rate, and in spring of 2017, CMS began imposing civil monetary penalties (CMPs) on Part D sponsors with demonstrated non-compliance with coverage determination and redetermination auto-forwards to the IRE. And with that, the die was cast.
Data universes are not new in the Medicare Advantage and Part D space. The Centers for Medicare & Medicaid Services (CMS) requires data universes for a variety of purposes, including program audits and timeliness monitoring. Gorman Health Group has communicated time and time again the importance of pulling accurate universes as well as continuous review of that data. Universes tell a story often not heard via other monitoring efforts.
On February 1, 2018, the Centers for Medicare & Medicaid Services (CMS) released its 2019 Advance Rate Notice (Part II) and Draft Call Letter. CMS estimates an expected increase of 1.84% to payments in 2019. CMS says its estimates do not reflect underlying coding trend, which it expects to increase risk scores by 3.1% in 2019.
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.
As 2018 and Year 2 of the chaotic Trump Administration kick off, trying to predict what will happen in Medicare, Medicaid, and the Affordable Care Act is as challenging as ever. It’s a midterm election year with terrible headwinds for the GOP, so the legislative calendar is abbreviated, and partisan rancor will peak. That makes it less likely Republicans will get to do much damage but also more likely they will try to serve up red meat for their base, like a return to “repeal and replace.” Congressional leaders, fresh off their billionaire bailout tax bill, are already talking about taking up “reform” (aka cuts) of Medicare and Medicaid and other social welfare programs. The only thing that is certain is 2018 will be another battleground year for government health programs.