Managing Medicare » Compliance http://dynamichealthsys.com/blog2 Information, Discussion, and Collaboration To Better Manage Medicare Businesses. Fri, 03 Dec 2010 17:56:46 +0000 en hourly 1 http://wordpress.org/?v=3.0.2 CMS Orders 3 Plans to Stop Marketing During 2011 AEP http://dynamichealthsys.com/blog2/2010/11/23/cms-orders-3-plans-to-stop-marketing-during-2011-aep/ http://dynamichealthsys.com/blog2/2010/11/23/cms-orders-3-plans-to-stop-marketing-during-2011-aep/#comments Tue, 23 Nov 2010 16:12:21 +0000 jbaker http://dynamichealthsys.com/blog2/?p=329 CMS has order three private MA plans to stop marketing and enrollment activity: Universal American Corp. (UAM), Health Net Inc. (HNT) and Arcadian Health.  Not a good time to stop enrolling members in the middle of the 2011 AEP!

Further References:

Kaiser Health News

Stockton (Calif.) Record: “These sanctions will remain in effect until each of the three plans demonstrates to CMS that it has corrected the related deficiencies and that those deficiencies are not likely to recur. The actions will not impact the 1 million Medicare beneficiaries enrolled in these health and drug plans” (11/23).

The Associated Press/Bloomberg Businessweek: “Health insurer Universal American Corp. said Monday federal regulators will suspend the company from enrolling new members in its Medicare Advantage plans as an open-enrollment period for the government-subsidized health coverage gets under way. The Rye Brook, N.Y., company said the suspension by the Centers for Medicare and Medicaid Services starts Dec. 5 and is tied mainly [to] agent oversight and market conduct issues. It said it was ‘working diligently’ to resolve the issues as soon as possible” (11/22).

]]>
http://dynamichealthsys.com/blog2/2010/11/23/cms-orders-3-plans-to-stop-marketing-during-2011-aep/feed/ 0
CMS Reiterates Standards for Selecting a Data Validation Contractor http://dynamichealthsys.com/blog2/2010/11/15/cms-reiterates-standards-for-selecting-a-data-validation-contractor/ http://dynamichealthsys.com/blog2/2010/11/15/cms-reiterates-standards-for-selecting-a-data-validation-contractor/#comments Mon, 15 Nov 2010 16:09:55 +0000 jbaker http://dynamichealthsys.com/blog2/?p=313 MA, MAPD and PDP plans are required to report measures to CMS for Part C and D benefits.  Additionally, plans are required to contract with an outside vendor to review and validate the data that was submitted to CMS. Attached is CMS’s standards that plans should use to select a validation vendor.

  • Vendor should be independent of the MAO and not involved in the submission process
  • Vendor should have previous experience in MA reporting requirements and technical specifications
  • HIPAA compliant
  • Prior experience in completing project of similar scope and size
  • Staff must complete CMS web-based CMS Data Validation Training

See the attached document for further details of the standards:

Standards for Selecting a DV Contractor 20101012

]]>
http://dynamichealthsys.com/blog2/2010/11/15/cms-reiterates-standards-for-selecting-a-data-validation-contractor/feed/ 0
CMS Publishes the 2011 Non-Matched NDC List http://dynamichealthsys.com/blog2/2010/10/25/cms-publishes-the-2011-non-matched-ndc-list/ http://dynamichealthsys.com/blog2/2010/10/25/cms-publishes-the-2011-non-matched-ndc-list/#comments Mon, 25 Oct 2010 17:15:59 +0000 jbaker http://dynamichealthsys.com/blog2/?p=282 CMS and the FDA are coordinating with each other to ensure the market is aware of the changes to the regulatory status of marketed prescription drug products. The Non-Matched NDC List represents drug products that have not been properly registered and listed with the FDA. The non-match FDA list is NOT to be used at a point of sale for approval or dis-approval of drug coverage. This list will change during the course of the payment year including retroactive changes to match and non-match status of NDCs.

The impact of a drug on the non mach list will result in a PDE transaction being rejected by CMS. As NDCs are added and removed, previously rejected PDEs may need to be resubmitted for acceptance with CMS.

CMS is recommending that plans monitor the FDA drug registration and listing changes to make correct point of sale coverage decisions and formulary changes during the course of the payment year.

Following is the HPMS CMS memo.

HPMSmemo2011NonMatchedNDCList_102210

]]>
http://dynamichealthsys.com/blog2/2010/10/25/cms-publishes-the-2011-non-matched-ndc-list/feed/ 0
Changes to DDPS (PDE) Edits on 1/1/2011 http://dynamichealthsys.com/blog2/2010/09/27/changes-to-ddps-pde-edits-on-112011/ http://dynamichealthsys.com/blog2/2010/09/27/changes-to-ddps-pde-edits-on-112011/#comments Mon, 27 Sep 2010 14:43:33 +0000 jbaker http://dynamichealthsys.com/blog2/?p=272 CMS provided new guidance on HMPS today on changes to their edit logic for PDE transactions submitted to CMS system, DDPS.

Summary of Changes:

  1. PLAN BID TABLE – New table that contains abbreviated plan bid information including the plan’s ICL, and application for supplemental benefit coverage
  2. MANUFACTURER AGREEMENT TABLE  - This will be the same information that CMS will publish that lists labeler codes for manufacturers that signed the Medicare Coverage Gap Discount Program Agreement.
  3. FDA BRAND / GENERIC TABLE – document New Drug Application (NDA) and Biologic License Application (BLA) marketing status as reported by the FDA

In addition to the new DDPS tables there are significant changes to the edit codes that CMS will be providing in the PDE Reply files.  I suggest your review these changes with your PBM and internal monitoring departments to ensure accurate reporting and monitoring of PDE data to CMS.

CMS’ focus to monitor all data submitted will include a focus on accurate and timely PDE reporting.

See the memo here: Prescription Drug Event (PDE) Edit Guidance Effective 1.1.2011 9.24

]]>
http://dynamichealthsys.com/blog2/2010/09/27/changes-to-ddps-pde-edits-on-112011/feed/ 0
DRAFT Plan Rating DATA – NOT to Be Used in Marketing Materials http://dynamichealthsys.com/blog2/2010/09/21/draft-plan-rating-data-not-to-be-used-in-marketing-materials/ http://dynamichealthsys.com/blog2/2010/09/21/draft-plan-rating-data-not-to-be-used-in-marketing-materials/#comments Tue, 21 Sep 2010 22:24:51 +0000 jbaker http://dynamichealthsys.com/blog2/?p=268 Today CMS sent a HPMS memo clarifying the use of DRAFT Plan Ratings Data that became available on 9/15/2010.  MA, MAPD and PDP plans should NOT use these rating scores in any marketing materials or communications.  There is the reality that potential findings from CMS or other Plan Sponsors may change final calculations and results of the ratings.  Only use the final results in communications.  CMS Memo below:

—————————-MEMO START——————————

Date: September 21, 2010

To: Part C and D Compliance Officers

From: Cynthia G. Tudor, Ph.D., Director, Medicare Drug Benefit and C & D Data Group

The data included as part of the Plan Ratings preview which began on September 15th are considered by CMS to be draft data. While we expect that the data that are posted in the preview will become final, there is the possibility that an error in a calculation could be found at some point during the preview period, either by a health or drug plan or by CMS. If that were to occur, then the possibility exists that your summary or overall rating would change as a result. Because these data are draft, CMS suggests that plans not incorporate these ratings into their marketing materials until such time as they are final.

Plan sponsors must provide the plan ratings template (which is generated from HPMS), and include it in their enrollment kits, using the prior year’s template information until such time as the template for the following contract year is made available. Once the current year’s plan performance rating template is available and final, plan sponsors may update the enrollment kit to ensure the most up-to-date plan performance ratings are provided to current and prospective enrollees. Plan rating information may not be altered relative to information on www.medicare.gov. Use of these data for marketing purposes must adhere to CMS marketing guidelines.

——————————END MEMO—————————–

]]>
http://dynamichealthsys.com/blog2/2010/09/21/draft-plan-rating-data-not-to-be-used-in-marketing-materials/feed/ 0
ECRS Webinar Training http://dynamichealthsys.com/blog2/2010/09/10/ecrs-webinar-training/ http://dynamichealthsys.com/blog2/2010/09/10/ecrs-webinar-training/#comments Fri, 10 Sep 2010 15:01:04 +0000 jbaker http://dynamichealthsys.com/blog2/?p=174 ECRS is the CMS contractor system used to submit changes in Coordination of Benefits information for Medicare members.  The contractor reviews the change requests.  Once the requests are verified they are confirmed back to the plan in the CMS COB file.  This process is key to maintain correct MSP information for members.  All plans need to understand these operational processes and develop policies and procedures to obtain and report correct COB information to CMS.  Getting this process right has a major impact on getting paid by CMS correctly.

I encourage you to attend this webinar and understand ECRS, COB and MSP better!

Here is the memo.

]]>
http://dynamichealthsys.com/blog2/2010/09/10/ecrs-webinar-training/feed/ 0
CMS Give Providers ‘Comparative Billing Reports’ to Self-Identify Erros http://dynamichealthsys.com/blog2/2010/09/07/cms-give-providers-comparative-billing-reports-to-self-identify-erros/ http://dynamichealthsys.com/blog2/2010/09/07/cms-give-providers-comparative-billing-reports-to-self-identify-erros/#comments Tue, 07 Sep 2010 15:25:50 +0000 jbaker http://dynamichealthsys.com/blog2/?p=170 In a significant move to reduce Fraud Waste and Abuse CMS has developed and is providing ‘Comparative Billing Reports’ to Medicare providers with the exception to Physicians and Inpatient hospitals.  I would expect to see many more investments in new processes, transparency and compliance requirements to identify errors and outliers in billing and the capability to correct these errors in a timely fashion.  All providers and government contractors will undergo continued growing scrutiny where outliers in billing and reporting practices will be audited and held accountable.

Read the complete AIS article here:  http://www.aishealth.com/Bnow/hbd090710.html

]]>
http://dynamichealthsys.com/blog2/2010/09/07/cms-give-providers-comparative-billing-reports-to-self-identify-erros/feed/ 0
Additional Changes to 2011 ANOC/EOC http://dynamichealthsys.com/blog2/2010/09/07/additional-changes-to-2011-anocepc/ http://dynamichealthsys.com/blog2/2010/09/07/additional-changes-to-2011-anocepc/#comments Tue, 07 Sep 2010 15:03:45 +0000 jbaker http://dynamichealthsys.com/blog2/?p=158 From CMS via HPMS on Sept 3, 2010:

“On August 11, 2010, we issued a memo describing corrections to the 2011 Annual Notice of Change/Evidence of Coverage.  We have the following additional corrections.

1 – Under the bullet, EOC Chapter 4, section 2.1, Your medical benefits and costs as a member of our plan, the standardized language should read, “Your provider will bill Original Medicare while your hospice election is in force.”

2 – Additionally, the current language in EOC Chapter 4, Kidney Disease Education Services, should read as follows:

“Education to teach kidney care and help members make informed decisions about their care.  For people with stage IV chronic kidney disease ,when referred by their doctor, we cover up to six sessions of kidney disease education services per lifetime.”

Please make the appropriate changes to your plan’s EOC, as applicable. Plans that have already submitted their EOC must resubmit the document with the revised language.  Please contact your Regional Office marketing reviewer if you have additional questions.”

]]>
http://dynamichealthsys.com/blog2/2010/09/07/additional-changes-to-2011-anocepc/feed/ 0
CMS Distributes CY 2011 Readiness Checklist http://dynamichealthsys.com/blog2/2010/09/07/cms-distributes-cy-2011-readiness-checklist/ http://dynamichealthsys.com/blog2/2010/09/07/cms-distributes-cy-2011-readiness-checklist/#comments Tue, 07 Sep 2010 15:00:47 +0000 jbaker http://dynamichealthsys.com/blog2/?p=151 That time of year again!  CMS has distributed via HPMS the 2011 MA and PDP Readiness memo.  Make sure you incorporate in your plan a review of the checklist and implement any corrective action to ensure your plan is in compliance.  CMS has been increasing their review of plans and this checklist is your compliance insurance. 

CY2011_Readiness_Checklist_090310

]]>
http://dynamichealthsys.com/blog2/2010/09/07/cms-distributes-cy-2011-readiness-checklist/feed/ 0
Deadline for QIP and CCIP Data Submissions Extended to Aug 27, 2010 http://dynamichealthsys.com/blog2/2010/07/24/deadline-for-qip-and-ccip-data-submissions-extended-to-aug-27-2010/ http://dynamichealthsys.com/blog2/2010/07/24/deadline-for-qip-and-ccip-data-submissions-extended-to-aug-27-2010/#comments Sat, 24 Jul 2010 14:58:28 +0000 jbaker http://dynamichealthsys.com/blog2/?p=138 All MA organizations (MAOs) that are effective before 1/1/2009 must submit a QIP and CCIP to CMS using their standard submission templates.  The templates can be found here:

http://optimalsolutionsgroup.com/CMS/index.html

Questions can be answered by the CMS contractor:

EMAIL:  maqro@optimalsolutionsgroup.com
PHONE: 866-962-6826

 CMS has extended the data submission deadline to Aug 27, 2010.  This is a compliance requirement so make sure your plan has a program to collect and report this information to CMS.

]]>
http://dynamichealthsys.com/blog2/2010/07/24/deadline-for-qip-and-ccip-data-submissions-extended-to-aug-27-2010/feed/ 0