Topic: Compliance

Industry Response to the Medicare Advantage Advance Notice and Draft Call Letter

Olga Walther

With the comment period to respond to the Centers for Medicare & Medicaid Services’ (CMS’) annual Medicare Advantage (MA) Advance Rate Notice and Draft Call Letter behind us, we now wait for the CMS response, expected April 3, 2017.

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Adjusting Star Ratings for Audits and Enforcement Actions

Regan Pennypacker

Within the Draft Calendar Year 2018 Call Letter, the Centers for Medicare & Medicaid Services (CMS) acknowledged the valuable comments received from the industry related to the use of audit findings and enforcement actions in the Star Ratings Program. As a result of those comments, CMS proposes a revision of the Beneficiary Access and Performance Problems (BAPP) measure.

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Will Trump and Price Pull Out the Scalpels for Star Ratings?

John Gorman

Star Ratings have driven the market in Medicare Advantage (MA) and Part D since the Affordable Care Act turned the consumer information tool into the biggest experiment in value-based payment on the planet. There’s little argument Star Ratings is working, and MA quality has improved. The program is being adopted in the ObamaCare Health Insurance Marketplace, and the Medicare Access and CHIP Reauthorization Act (MACRA) included the Quality Reporting System, or Stars for Medicaid, starting in 2019. Then Trump got elected President and appointed Tom Price the Department of Health and Human Services (HHS) Secretary. Could they pull out the scalpels for Star Ratings?

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How to Maximize Your Medicare Advantage Website Strategy

Angela Fox

How was your Annual Election Period (AEP)? Have you evaluated your performance? Do you need to enhance your sales and marketing strategies? Now is the time to recognize and appreciate your 2017 successes as well as confront your shortcomings.

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The Part D Shell Game

Debra Devereaux

Top of mind when we are talking about Medicare compliance should be that the ultimate customer is the taxpayer who funds this program. That’s why the Centers for Medicare & Medicaid Services (CMS) has to attempt to account for every nickel that comes into or goes out of the programs. One of the murkiest finance areas is in Medicare Part D – that is Direct and Indirect Remuneration (DIR). CMS published a memo on January 19, 2017, with this very title.¹ DIR is the additional compensation – besides a partially capitated payment from CMS – received by a plan sponsor or Pharmacy Benefit Manager (PBM) after the pharmacy point of sale (POS) transaction. This changes the final cost of the drug for the plan sponsor or the price of the drug paid to the pharmacy. DIR has grown significantly in the past few years in large part because of the growth of preferred network pharmacies. CMS states they have observed “a growing disparity between gross Part D drug costs, calculated based on costs of drugs at the POS, and net Part D drug costs, which account for all DIR.”

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A Vendor’s Oversight is Never Done

Regan Pennypacker

There are many industry voices adding their perspectives about the new administration and changes to come. However,  the Compliance Officers I know do not have the luxury of stopping and truly considering the potential impact as they are managing the continuous pressures of their daily directives. Today I address a group of very industrious Compliance professionals not often addressed, and those are the staff responsible for Compliance Programs at first tier, downstream and related entities, or “FDRs.” Under Medicare regulations, plan sponsors may enter into contracts with FDRs to provide administrative or healthcare service functions on their behalf.

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It’s Product, Benefit, and Premium Time for 2018

Diane Hollie

Whether you are just updating your current product benefits, are offering a new plan benefit package (PBP), new product, or service area, or are new to Medicare Advantage altogether, now is the time to start planning for the 2018 bid submission.

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