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Topic: Part D
On September 13, 2016, the Centers for Medicare & Medicaid Services (CMS) quietly released its long-awaited proposed methodology on the calculation of Civil Money Penalties (CMPs). The memo describes the calculation method of CMPs for Medicare Advantage Organizations (MAOs), Prescription Drug Plans (PDPs), Cost Plans, and Programs of All-Inclusive Care for the Elderly (PACE) plans in 2017. While CMS is not mandated to release this methodology, it did so in response to industry concern over transparency of CMP calculation and to provide more clarity to compliance operations. Comments on the proposed methodology are due to CMS by 5:00 p.m. ET on October 13, 2016.
Your Pharmacy Benefit Manager (PBM) may have already provided to you their benefit testing pan for 2017. Based on many years of experience, that is not going to be enough. In the September 12, 2016, memo entitled â€œContract Year 2016 Part D Formulary Administration Analysis (FAA)â€, the Centers for Medicare & Medicaid Services (CMS) reiterates their concern with the accuracy of formulary coding. In previous yearsâ€™ analysis, 9 out of 88 (10. %) Plan Sponsors were found to have failed FAA, meaning greater than 20% of the sampled rejects were determined to be inappropriate. The parameters for the 2016 FAA are: Read more
The Centers for Medicare & Medicaid Services (CMS) released its annual Medicare Advantage (MA) and Part D â€œlandscape filesâ€ with data on plans and bids for 2017. Itâ€™s a picture of programs that are rock-solid and driving insurersâ€™ revenues and earnings, offering better supplemental benefits for no increase in price for two-thirds of beneficiaries. Interestingly, CMS appears to be sandbagging its enrollment projections and assumed no growth for MA in 2017. We think weâ€™re heading to 4.2-4.5% enrollment growth, continuing a steady, winning drumbeat for the industry.
According to Author Stephen Covey, in his book The Seven Habits of Highly Effective People, you should â€œbegin with the end in mind.â€ This means to start with a clear understanding of your destination so you know where you’re going and understanding where you are now so the steps you take are always in the right direction.