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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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What Risk Does the new TERM Table Really Pose?

| Audits, Medicare, Part D, Spring 2024, Utilization Management | No Comments
Have you heard about the new table initially required in the CMS Utilization Management (UM)-Focused audits? Also, known as “Table 7”, Plans need to ensure an ability to report accurate…

What we know so far about 2024 Utilization Management Focused Audits

| Audits, CMS, Spring 2024 | No Comments
On April 12, 2023, the Centers for Medicare & Medicaid Services (CMS) released the 2024 Final Rule in the Federal Register (2024 Final Rule).  Among other provisions, the Final Rule…

The Part D Tongue Twister and Brain Teaser also known as the Medicare Prescription Payment Plan

| IRA, Part D, Spring 2024 | No Comments
The Inflation Reduction Act (IRA) was signed into law in August 2022 with the goal of expanding Part D benefits, lowering drug costs, and improving the sustainability of the Medicare…

The Importance of Medicare Marketing Material Development and Review, New changes coming and 2024 finding examples

| CMPs, CMS, IRA, Medicare, NABA, NONC, Part D, Spring 2024 | No Comments
Member materials are an important part of the Medicare member experience with a plan. Each year as Plan Sponsors finalize their product bid filing, CMS releases the upcoming plan year…

The Centers for Medicare & Medicaid Services: 2024 Readiness Checklist for Medicare Advantage Organizations, Prescription Drug Plans

| CMS, December 2023 | No Comments
The Centers for Medicare & Medicaid Services (CMS) released the CY2024 Medicare Parts C and D Readiness Checklist on October 13, 2023. Although this is a busy time of year,…

Special Supplemental Benefits for the Chronically Ill: 2025 Proposed Rule Impacts to Consider

| CMS, December 2023, HHS, SSBCI | No Comments
Believe it or not, it is already time to start thinking about plan benefits for contract year 2025. Plan sponsors continue to look for ways to grow membership, modify benefit…

Is Your Part D Stars Program Ready to Ring in the New Year?

| December 2023, Opioids, Part D | No Comments
On April 12, 2023, Centers for Medicare & Medicaid Services (CMS) published the 2024 Final Rule that postponed moving the three polypharmacy measures (Concurrent Use of Opioids and Benzodiazepines, Polypharmacy…

Inflation Reduction Act (IRA): 2024 Summary of Changes and Oversight Considerations

| CMS, December 2023, IRA | No Comments
The Centers for Medicare & Medicaid Services (CMS) has released significant guidance to support the Inflation Reduction Act (IRA) provisions that impacts Medicare enrollees, health plans, pharmacy benefit managers (PBM)…

Consultant Corner: Strategic Planning: Using the Notice of Intent to Apply timing to trigger potential opportunities with your leadership and Board of Directors

| AEP, September 2023 | No Comments
Wendy Edwards, MPA, CHC, CHPC, is Director of Internal Operations at BluePeak Advisors, a division of Gallagher Benefit Services, Inc. Preparing for 2025 may not be at the top -of-mind…

Classifying An Enrollee Billing Complaint as a Grievance, Coverage Request, or Both?

| Claims, September 2023 | No Comments
When an enrollee contacts the plan about a provider’s bill, it can be challenging to determine if the enrollee’s issue should be classified as an inquiry or processed under the…

Changes to CMS Requirements for Translation and Alternate Formats

| FDR, MA, Part D, September 2023 | No Comments
To ensure effective communication and meaningful access, Medicare Advantage (MA) and Prescription Drug Plans (PDPs) have been obligated to follow various, occasionally interconnected directives for translating member documents into different…

2024 National Average Monthly Bid Amount Impact

| PBM, September 2023 | No Comments
On July 31, 2023, Centers for Medicare & Medicaid Services (CMS) released the National Average Monthly Bid Amount (NAMBA) for contract year (CY) 2024.  For 2024, the national average bid…

Prepared to Implement the CMS Preclusion List Requirement?

| CMS, Part D | No Comments
Along with the new year also comes a new CMS requirement known as the Preclusion List. This requirement was adopted in the April 2018 final rule as an alternative to…

Top 4 Tips to Make 2022 Your Best Plan Year Yet

| Audits, CMS, Tips | No Comments
As we are begin the last quarter of 2021, Plans are thinking about readiness for January 1st. Below are just a couple of the areas that BluePeak suggests plans look…

Reconciling Skilled Nursing Facility Drugs Payment

| Audits, Part D, SNF | No Comments
Recent 1/3 Financial Audits have focused on the accuracy of billing of medications while a member is in a skilled nursing facility (SNF).   Most drugs administered during an acute stay in…

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…

Annual Enrollment Period (AEP) is Right Around the Corner-From Bid to Enrollment Processing

| AEP, Audits, Enrollment | No Comments
8 Tips to Ensure Your Plan is Ready After months of hard work and planning, everyone sighed with relief when bids and formularies were submitted earlier this month.  But, as…

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,…

Want to know what you missed if you didn’t receive an audit notice in 2022?

| Consultant Corner | No Comments
Carmen Winters, a BluePeak senior consultant, provided 2022 CMS program audit support to many clients. Read about her observation regarding CMS auditor focus on Quality of Care during the 2022…

Annual Transition Policy and Attestation Submission to CMS

| CMS, HPMS, Part D | No Comments
The Centers for Medicare and Medicaid Services (CMS) requires, as part of the formulary submission process, each plan sponsor  complete the Transition Policy Attestation through the formulary submission module in…

Will Your Grievance Resolution Letters Stand Up in an Audit?

| Audits, CMS, Medicare, Part D | No Comments
Across the Medicare Advantage and Part D industry, Plans are nervous about how their grievance resolution letters will present and stand the test in a CMS Program Audit. BluePeak Advisors…

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…

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…

Cost of Non-Compliance

| CMPs, CMS, Medicare, Part C, Part D | No Comments
Did you know... Forty-six percent of sponsors subject to a 2016 Program Audit received a Civil Money Penalty (CMP) for violations of Medicare Parts C and D requirements found by…

2018 is Around the Corner – Are You Ready?

| ANOC/EOC, CMS, Compliance, CPE, CTM, HPMS, PBM, Uncategorized | No Comments
Bid approved – check. Member materials sent to printer – check. What other items should be on your radar over the next few months? The Centers for Medicare and Medicaid…

Third Party Marketing Organization (TPMO) Requirements – Not just a Sales Department Responsibility

| June 2023, TPMO | No Comments
If it seems as though the Centers for Medicare and Medicaid Services (CMS) has increased its focus, oversight and scrutiny on the marketing practices of some agents and brokers for…

Accurate Call Classification and Handling-Strategies for Evaluating and Monitoring Your Customer Service Team

| Audits, Call Log Review, CMS, Part C, Part D, Star Ratings | No Comments
The Centers for Medicare & Medicaid Services (CMS) released an HPMS memo on August 20, 2019 providing an overview of the upcoming changes to program audits through 2021. These changes…
prescription drugs

PDE SELF AUDITS in 2018

| CMS, Part C, Part D, PDE | No Comments
Throughout 2017, CMS continued its vigilance over drug claim payments by conducting Prescription Drug Event (PDE) Self-Audits. The drugs under audit in 2018 may change, but CMS has not yet…

‘Tis ALWAYS the season….for rejected claims analysis.

| CMS, PBM | No Comments
As year-end approaches, most plans are conducting claims testing to ensure that formularies and benefits are administered correctly on January 1 and beyond.  Plans and PBMs alike that have experienced…

ICYMI – BluePeak’s Articles Posted Recently On LinkedIn

| Ask the Expert, LinkedIn | No Comments
BluePeak's Summary on COVID-19 Gallagher Special Olympic partnership COVID-19 Medicare Fact Sheet 10 Things Plan need to know about the Proposed Rule   Kelly MaKay, RPh, MBA Senior Health Plan Services…
finger on a map

CMS Increases Scrutiny of FDRs, Finds Common Conditions During 2017 Program Audits

| CDAG, CMS, CPE, FDRs, ODAG, TPMA | No Comments
During the 2017 audit season, BluePeak observed increased CMS increased scrutiny on plans and their First Tier, Downstream and Related Entities (FDRs), as well as repeated Common Conditions. With limited changes from…
Tips

BluePeak Offers Tips for Developing 2018 Risk Assessments and Monitoring and Auditing Work Plans

| Audits, CMS, CPE, FDRs | No Comments
Annual risk assessments and associated monitoring and auditing work plans are not only required, but also help to ensure your compliance program is efficiently and effectively monitoring and auditing business…
Street signs one stating 2018 and pointing left, the other stating 2019 and pointing right

Getting Ready for Early Application Tasks and Understanding 2019 Application Changes

| CMS, HPMS, Medicare, Uncategorized | No Comments
Submit Notice of Intent to Apply (NOIA) Now Each year, the Centers for Medicare and Medicaid Services (CMS) accepts applications from new plan sponsors, as well as existing Medicare Advantage-Prescription…

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…

OIG finds MAOs Inappropriately Denying Requests for PA and Payment, CMS agrees to Issue Stricter Guidance and update Audit Protocols and Auditor Training

| MAO, OIG | No Comments
In late April, the U.S. Department of Health and Human Services Office of Inspector General (OIG) released their detailed findings concerning inappropriate denials of prior authorization (PA) requests and payment…

Highlights of Proposed 2020 Audit Protocols

| Audits, CMS, HPMS, Medicaid, Medicare | No Comments
The Centers for Medicare & Medicaid Services (CMS) released an HPMS memo on August 20, 2019 providing an overview of the upcoming changes to program audits through 2021.  These changes…

In Case You Missed It! CMS New Marketing Module Training–Big Changes Coming

| CMS, HPMS, MCMG | No Comments
On Friday May 28th, at 5pm ET, CMS will provide Plan Sponsors access to the new HPMS marketing module.  The new marketing material module has enhanced functionality and will provide…

ICYMI – BluePeak’s Articles Posted Recently On LinkedIn

| LinkedIn | No Comments
Looking for more articles and insight from us? Head over to our LinkedIn page to discover more. Here are some of the recent articles posted there: CMS Announces Timeliness Monitoring…

Along with Other Trends, CMS Cites Common and New Findings in 2018 Program Audits

| Audits, CDAG, CMS, CPE, FA, ODAG, SNP-MOC | No Comments
The end of September marks the end of the full 2018 Centers for Medicare and Medicaid Services (CMS) Program Audit season. Plans that have not yet received an audit engagement…

Medicare Advantage and Prescription Drug Plan Appeals Guidance– Are You Ready?

| HPMS, Medicare, PDBM | No Comments
Chapter 13 of the Medicare Managed Care Manual (MMCM) and Chapter 18 of the Prescription Drug Benefit Manual (PDBM) have been consolidated into one chapter. CMS announced the release of…

CY 2022 Part C and Part D Reporting Technical Specifications – Do You Know What Has Changed?

| Fall 2022, Medicare | No Comments
In June, CMS issued updated technical specifications for CY 2022 Medicare Part C and Part D reporting. BluePeak has summarized the key changes in the technical specifications below. BluePeak compared…

Avoiding a Perfect Storm-Proactive Testing and Claims Oversight is Key

| Compliance | No Comments
The most effective way for any plan to avoid member disruption and compliance risks for the new plan year is to establish a process to validate the accuracy of the…
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