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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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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…

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…

BluePeak Service Spotlight: Member Material Review

| CMS, EOBs | No Comments
BluePeak’s consultants have experience reviewing member materials from their work at Plans and for the Centers for Medicare and Medicaid Services (CMS). We can help you populate and/or review 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…
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…

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…

Proposed Rule Aimed at Drug Price Transparency Could Lead to Inadvertent Member Confusion

| CMS, Medicare, Part C, Part D, PBM | No Comments
On October 18, 2018, the Centers for Medicare & Medicaid Services (“CMS”) published a proposed rule which, if finalized, will amend the Medicaid and Medicare Parts A, B, C, and…

Service Spotlight: End-to-End Part C Claims Testing

| Service Spotlight | No Comments
Now that bids have been submitted, it is time to start thinking about 2022 compliance and operations. One of the best ways to prepare for audit success and happy members…

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…

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…

Audit Experiences Underscore the Importance of the Additional Beneficiary Information Initiatives (ABBI) Database

| Audits, CMS, MA-PD, PDE | No Comments
Prior to 2019, plan sponsors were required to make an effort determine whether an immunosuppressant should be paid under Part D or Part B based upon information they had or…

Appeals and IRE Data Issues Can Impact Audit Scores, Star Ratings and CMPs  

| CDAG, CMPs, ICARs, IRE, ODAG | No Comments
Whether deficiencies are discovered as part of a CMS program audit or a Timeliness Monitoring Project (TMP) review, issues with appeals and Independent Review (IRE) data can impact a plan’s Star Ratings…

Biden Administration Immediate Actions May Affect Health Plans

| Uncategorized | No Comments
President Biden hit the ground running, signing a batch of Executive Orders just hours after he was sworn in as the 46th President of the United States.  A couple of…

Proposed Changes to MA and Part D Prescription Drug Program Quality Rating System from the  2021 and 2022 Policy and Technical Changes Proposed Rule

| CMS, QBP, Star Ratings | No Comments
In the 2021 and 2022 Policy and Technical Changes Proposed Rule, CMS is proposing routine measure updates and an increase in the weight of patient experience/complaints and access measures. It…

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…

CMS Releases 2022 Audit Protocols

| Audits, CDAG, CMS, ODAG, Part C, Part D | No Comments
With the 2021 Program Audit in full swing, CMS released the Program Audit Protocols for 2022 on May 26, 2021.    The 2022 protocols are very similar to what was previously…

Effective Strategies in Claims Quality Auditing

| MA, November 2022 | No Comments
In light of ever rising benefit costs, employers and Medicare Advantage (MA) plans should consider regular claims quality auditing as part of an overall benefits and cost-containment strategy. Claims audits…

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…

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…

‘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…

Time to Dive into Self-Audit Season

| CMS, DME, ESRD, FDA, Part B, Part D | No Comments
In addition to CMS performing numerous program audits thus far in 2021, recent memos have denoted that CMS is moving forward with several self-audits for plans to consider.  In April,…

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…

97% Isn’t Good Enough: Why Every Decision Matters

| Fall 2022, ODAG | No Comments
The Organization Determinations, Appeal and Grievances (ODAG) area of a Centers for Medicare & Medicaid Services (CMS) Program Audit focuses on high-risk areas with the greatest potential for enrollee harm. …

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…

Calling All SNP Plans

| News Alert | No Comments
Is your Special Needs Plan (SNP) due for a 2025 Model of Care (MOC) submission? With a due date of February 2024, we encourage you to not wait to review…

Past Performance, Encounters and Misclassifications, Oh My!

| Audits, CMS, Compliance, Part C, Part D, Past Performance, Uncategorized | No Comments
CMS denies applications due to Past Performance scores, encounter data volume is growing, and misclassification of appeals and grievances continues to be an issue. BluePeak tells you what you need…

BluePeak’s Summary of the September 2018 Medicare Communications and Marketing Guidelines (MCMG)

| CMS, Marketing, MCMG | No Comments
On July 20, 2018, the Centers for Medicare & Medicaid Services (“CMS”) released the Medicare Communications and Marketing Guidelines (“MCMG”), replacing the Medicare Marketing Guidelines and all associated guidance in…

Consultant Corner: Inflation Reduction Act Implementation Best Practices and Planning for the Future

| Consultant Corner, IRA | No Comments
Jeff Baker, is a BluePeak Senior Health Plan Services Consultant. On August 16th, the Inflation Reduction Act of 2022 (IRA) was signed into law.  The text of the bill is…

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…

Consultant Corner: “See One, Do One, Teach One”

| Audits, Consultant Corner, Spring 2024 | No Comments
Lisa B. Barker MBA, BSN, RN, CCM is a Senior Consultant, Part C Lead with BluePeak Advisors, a division of Gallagher Benefit Services, Inc. “See One, Do One, Teach One”…

10 Things Plans Need to Know about the 2021 and 2022 Policy and Technical Changes Proposed Rule

| DMP, MA, PACE, Part C, Part D, RTBT | No Comments
On February 5, 2020, the Centers for Medicare & Medicaid Services (CMS) announced it will not be publishing a Call Letter for 2021.  Rather, CMS is codifying guidance typically published…

5 Universal Strategies to Move the Needle on Star Rating Improvements: A Medication Adherence Case Study

| Medicare, Part C, Part D | No Comments
One of the surprises in the release of plans’ Star Ratings results for the 2019 open enrollment season was that Star Ratings around Part D adherence scores, on average, slipped.…
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