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BluePeak Bulletin

Since its inception, BluePeak has been committed to making the complicated world of government-sponsored healthcare programs easier to navigate. BluePeak employees pride themselves on delivering outstanding consulting services to our varied clients through our motto of Knowledge, Experience, and Trust. Read through our past articles from our quarterly newsletters and news alerts.

Get the latest news and regulatory updates through our quarterly newsletter, BluePeak Bulletin, and our BluePeak News Alerts. Subscribe today to get these BluePeak publications directly to your inbox.

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As we navigate the evolving landscape of healthcare regulations, BluePeak is dedicated to helping you manage these complexities and ensure compliance with all requirements. We are preparing a special edition to deliver the latest updates and insights directly to your inbox. Subscribe today to stay informed. For more information on how BluePeak can assist you, please email us at [email protected].

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Proposed Rule Re: Medicare Program

| CMS, PACE, Part C, Part D, Winter 2024 | No Comments
Proposed Rule Re: Medicare Program; Contract Year 2026 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicare Cost Plan Program, and Programs of All-Inclusive…

Risk-Adjustment Data Validation Readiness: Key Strategies for Compliance

| CMS, HCC, OIG, Winter 2024 | No Comments
Did you know that there are publicly accessible resources identifying highly scrutinized Hierarchical Condition Category (HCC) codes that may be problematic for your plan? Did you know there’s an annual…

Navigating the Future of Utilization Management Requirements

| Part D, Utilization Management, Winter 2024 | No Comments
As 2024 comes to a close, the Centers for Medicare & Medicaid Services (CMS) Utilization Management (UM) requirements remain as high priority, and 2025 brings with it new considerations for…

Medicare Prescription Payment Plan – Are you ready for it?

| IRA, MPPP, Winter 2024 | No Comments
The Inflation Reduction Act (IRA) introduced several changes to the Medicare landscape.  One of the biggest changes that impacts members and plans alike is the Medicare Prescription Payment Plan (MPPP)…

Part D Audit Insights for CY2024: Key Takeaways

| Fall 2024, Part D | No Comments
As the CY2024 audit season wraps up, the Centers for Medicare and Medicaid Services (CMS) has been publishing both draft and final reports for those selected for program audits. We…

Should Off-cycle MOC Submission Be a Priority, RIGHT NOW?

| Fall 2024, MOC, NCQA | No Comments
December 1, 2024, signals closure of the 2024 the National Committee for Quality Assurance (NCQA) Model of Care (MOC) Off-Cycle submission window, but there is still time to update if you…

2024 Audit Trends: Special Needs Plans

| Audits, Fall 2024 | No Comments
The 2024 the Centers for Medicare and Medicaid Services (CMS) audit season brought a diverse array of trends for Special Needs Plans (SNPs) yet one consistent and notable emphasis prevailed:…

2025 Plan Readiness: Are You Prepared?

| CMS, Fall 2024, IVR, M3P, Member Materials, Part C, Part D, SSBCI | No Comments
As you put the final touches on Plan Year 2025 implementation, it is crucial for Medicare plans to stay ahead of the game and be prepared for the changes that…

Upcoming IRA Changes for 2025: Key Considerations for Year End Testing

| Audits, CMS, Summer 2024 | No Comments
Since its passage, the Inflation Reduction Act (IRA) of 2022 has ushered in changes to the Medicare Part D benefit each contract year (CY) and 2025 is no different. Now…

Understanding Dual-Eligible Special Needs Plans (D-SNPs): Your essential guide to types of D-SNPs and the impact of MMPs Sunsetting

| CMS, D-SNP, MMP, Summer 2024 | No Comments
In May of 2022, CMS finalized the rule that will sunset Medicare-Medicaid Plans (MMPs).  This rule proposes that required states transition their MMP enrollees to integrated Medicare Advantage dual eligible…

Consultant Corner: Updates to the Plan Communication User Guide That Require Attention

| Audits, Consultant Corner, Summer 2024 | No Comments
Meryl Chick is a Consultant with BluePeak Advisors, a division of Gallagher Benefit Services, Inc. Are you monitoring the Batch Completion Status Summary (BCSS)? If the answer is no and…

2024 Utilization Management (UM)- Focused Audits: Lessons Learned

| Summer 2024, Utilization Management | No Comments
The annual Centers for Medicare and Medicaid Services (CMS) Audit Season has been in full swing since the beginning of the year with a focus on Utilization Management.  CMS is…

In the News…

| FDA | No Comments
Unapproved Drugs Initiative Terminated On November 20, 2020 The Department of Health and Human Services terminated the Unapproved Drugs Initiative. The 2006 Unapproved Drug Initiative requires manufacturers to submit drugs…

Should Off-cycle MOC Submission Be a Priority, RIGHT NOW?

| Fall 2024, MOC, NCQA | No Comments
December 1, 2024, signals closure of the 2024 the National Committee for Quality Assurance (NCQA) Model of Care (MOC) Off-Cycle submission window, but there is still time to update if you…

Rethinking Your Risk Adjustment “Risk Management” Program

| FDR, OIG | No Comments
Risk adjustment is expected to receive additional focus and attention from federal regulators in the near term.  Political and administrative changes frequently shift the focus and attention of oversight agencies,…

Senior Savings Model-Tips for a Successful Implementation

| Claims, CSR, Formulary, Part D | No Comments
Participation is expected to be strong in the Part D Senior Savings Model launch on 1/1/21 with 1,750 plans across 88 sponsors and 3 manufacturers participating in the program.  Participating…

CMS Annual Report Shows Audit Scores and CMPs Decreased, Common Conditions Repeated in 2017

| Audits, CMPs, CMS, CPE | No Comments
From 2016-2017, audit scores were lower in all areas, except Compliance Program Effectiveness (CPE); Civil Money Penalties (CMPs) were significantly reduced; and most Common Conditions were repeated, according to the…

Formulary Strategy Planning for 2020-Indication Based Formulary Design Considerations

| CMS, EOC, FDA, Part D | No Comments
The 2019 plan year has not commenced, yet plans are already developing formulary strategies for 2020. Indication-based formulary designs will add a new twist for plan sponsors to consider as…

Big Changes Ahead for Group Health Plans and Individual Health Plans

| Legal, Summaries | No Comments
The following are summaries of Rules that contain big changes for group health plans and individual health plans. SummaryInterim Final Rule with Comment Period Requirements Related to Surprise Billing; Part…

Inflation Reduction Act (IRA) Drug Rebate Program and Drug Price Negotiation

| IRA, June 2023 | No Comments
CMS has been very active in releasing significant guidance to support the Inflation Reduction Act (IRA) provisions for the Part Drug Inflation Rebate and the Drug Price Negotiation program.  Earlier…

Top 5 Tips to Prevent a Part D Transition Finding

| Tips | No Comments
Transition is highly scrutinized and frequently audited within the Medicare Part D program. For 2021, the Centers for Medicare & Medicaid Services (CMS) performed the Transition Requirements Analysis (TRA) to…

CMS Continues to Scrutinize Part D Claims and Coverage Determinations Process through Program Audits and Notices of Non Compliance

| Fall 2022, Part D | No Comments
CMS Program Audit season is over and as anticipated, the volume of Program Audits in 2022 increased substantially over prior years. From a Part D perspective, audits have touched almost…

NEWS ALERT – 12/27/2022

| News Alert | No Comments
BluePeak’s releases index on the entire proposed rule contents December 27, 2022, CMS published proposed rule CMS FRDOC 001 regarding Medicare Program; Contract Year 2024 Policy and Technical Changes to…

BluePeak Releases Summaries and Webinar Covering 2019 Call Letter

| Call Letter | No Comments
Bluepeak Subject Matter Experts (SME) have reviewed the 2019 Call Letter and created the following for your reference. 2019 Call Letter Summary Detailed overview of this year’s changes and what…

What You Need to Know About Sections 504, 508 and 1557

| Compliance, Section 1557, Section 504, Section 508 | No Comments
You likely saw that CMS recently released a FAQ document on Section 504 and Section 1557. This FAQ document provides clarity on requirements that several organizations have been questioning since…

Significant Changes Proposed for Qualified Health Plans

| ACA, CMS, CSR, FFE | No Comments
The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule titled “Patient Protection and Affordable Care Act; Updating Payment Parameters, Section 1332 Waiver Implementing Regulations, and Improving…

Proposed American Jobs Plan Includes Provision for Medicaid

| Medicaid | No Comments
On March 31, 2021, President Biden, as part of the White House American Jobs Plan, proposed to increase federal support for home and community-based care by $400 billion over eight years…

Potential Changes on the Horizon for 2020 and Beyond

| CMS, FDRs, HPMS, Medicaid, Medicare, Star Ratings, TPMA | No Comments
After getting ready for all the changes a new contract year brings, Medicare Advantage (MA) Plans and Part D sponsors await the issuance of the Draft Call Letter for early…

Initial Adoption of Indication-Based Formularies as a Formulary Management Tool

| CMS, Medicare, Part D | No Comments
In August of 2018, CMS announced that Medicare Part D Sponsors have the option to use indication-based formularies starting January 1, 2020.  Prior to this change, formulary medications were considered…

Highlights of the Final Rule

| CMS, Medicare, PACE | No Comments
Contract Year 2022 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicaid Program, Medicare Cost Plan Program, and Programs of All-Inclusive Care for the…
laptop and stethoscope

You’re Going to Want BluePeak’s Online Provider Directory Review Service

| CMS, Medicare, News, Uncategorized | No Comments
From February to August, the Centers for Medicare & Medicaid Services (CMS) conducted the second round of online provider directory reviews of 64 Medicare Advantage Organizations (MAOs). CMS reviewed online…

BluePeak Service Spotlight: HIPAA Program Review

| HIPAA, OCR | No Comments
HIPAA Violations = Potential Civil Fines and Criminal Penalties How healthy is your HIPAA Program?  BluePeak’s HIPAA Program Review can help you identify and correct privacy, security and breach policy and procedure issues that might leave…

Ensuring a Pain-free Opioid Safety Strategy

| CARA, CMS, MME, OMS, Opioids, Part D | No Comments
In 2019, Medicare introduced new policies for opioid prescriptions in the Medicare Part D prescription drug program to encourage pharmacies, prescribers, and Medicare drug plans to work together with the…

BluePeak Podcast: Cost of Non-Compliance

| CMPs, CMS, Podcast | No Comments
The Facts are Sobering: CMPs may be the least expensive part of being non-compliant. CMS audits are on the rise, as are CMPs and sanctions. The average CMP is around…

The PDE Submission Deadline is Rapidly Approaching-Don’t Assume a High Acceptance Rate Translates to PDE Accuracy

| CMS, Compliance, PBM, PDE | No Comments
The 2021 PDE submission deadline is June 29, 2022.  Plans must attest to the accuracy of their submitted PDE records prior to CMS’ financial reconciliation.  The challenge is that many…

Is Your Plan Ready for the New Year?

| CMS, MBI, Medicare, Open Enrollment, Part D | No Comments
Annual Notices of Changes (ANOC) shared with enrollees Evidence of Coverage (EOC) shared with enrollees Formulary shared with enrollees Pharmacy and Provider Directories shared with enrollees Medicare Communications Marketing Guidelines…

Top 10 Audit Tips

| Audits, CMS, Tips | No Comments
Here are some tips to help ensure your Plan is adequately prepared as audit season gets underway for 2021. Ensure your plan and all of its delegates can produce accurate…

CMS Releases a Flurry of Interim and Final Rules

| CMS, COVID19, HPMS | No Comments
CMS released several interim and final rules in the past month.  As the new year starts and there is a change in administration, the pace of new guidance releases is…

Risk-Adjustment Data Validation Readiness: Key Strategies for Compliance

| CMS, HCC, OIG, Winter 2024 | No Comments
Did you know that there are publicly accessible resources identifying highly scrutinized Hierarchical Condition Category (HCC) codes that may be problematic for your plan? Did you know there’s an annual…

Perfect Storm

| CMS | No Comments
The last quarter of 2020 will likely be the most significant and the most challenging testing season plans have experienced.  Unfortunately, there may be a perfect storm brewing that is…

Service Spotlight: Comprehensive Support from Bid to AEP and Beyond…

| AEP, MCMG, Member Materials, Part D | No Comments
On February 9, 2022 CMS released the Medicare Advantage and Part D Communications & Marketing Guidelines (MCMG) reminding us all of what we already know- it’s time to begin planning…

Risks in Misclassifying First Tier, Downstream, and Related Entities (FDRs)

| MA, MCMG, Medicare, November 2022 | No Comments
There are a number of criteria outlining the oversight of First Tier, Downstream and Related Entities for Medicare Advantage Organizations.  Chapters 21 / 9 and 11 of the Medicare Managed…
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