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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.

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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 info@bluepeak.com.

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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…

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…

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…

2023 CMS Program Audit Trends and Key Details: What We Know So Far

| CDAG, CPE, FA, June 2023, ODAG, SNP-MOC | No Comments
On November 30, 2022, the Centers for Medicare and Medicaid Services (CMS) Medicare Parts C and D Oversight and Enforcement Group (MOEG) announced the 2023 program audit updates.  CMS is…

BluePeak provides fresh insight into the CMS Proposed Rule for 2024

| February 2023, Medicare, Part A, Part B, Part C, Part D | No Comments
On December 27, 2022, the Centers for Medicare & Medicaid Services (CMS) published proposed rule (CMS_FRDOC_0001-3474) in the Federal Register. If finalized, this proposed rule would revise the Medicare Advantage…

Civil Money Penalty Actions and Audit Trends

| Audits, CMPs, CMS | No Comments
On 2/28/2020, CMS released the Civil Money Penalty (CMP) Enforcement Actions for 2019 Program Audits.  Contract year 2019 was the first year of this audit cycle and we have incorporated…

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,…

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…

Ensuring Record Retention Requirements with First-tier, Downstream and Related Entities (FDR’s).

| FDRs, Medicare, Part D, Uncategorized | No Comments
Many Medicare Plans may believe compliance with the ten-year record retention requirement is a slam-dunk.  However, plans are often tripped up in audits because their first-tier and downstream entities do…

Transition Monitoring Program Audit-Coming Soon!

| CMS, TPMA, Uncategorized | No Comments
History and Methodology The transition monitoring program analysis (TMPA) has been in effect since 2012 and will likely be a staple in the Part D program for several years to…

New OD/CD Withdrawal Guidance Released

| CMS, Medicaid, Medicare, Part C, Part D | No Comments
NEW! Beginning January 1, 2022, plans must send a written notice of dismissal for Part C OD and reconsideration requests as well as for Part D CD and redetermination requests…

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…

Minimizing Hospice Billing Concerns

| CMS, November 2022, Part D | No Comments
What is the Issue?1 In August 2019, the Department of Health and Human Services Office of Inspector General (OIG) released a report entitled, Medicare Part D is Still Paying Millions…

CMS Continues to Deploy Revised Strategies to Assist with Identifying and Deterring Opioid Abuse

| CMS, MAT, Medicare, MME, Opioids, Part D, PBM | No Comments
To assist Medicare Part D sponsors with monitoring efforts and potentially avoid overutilization of opioids in the elderly Medicare population, CMS has deployed numerous strategies over the past several years…

CMS Updates Definition of Marketing, Reduces Required Hard Copy Member Materials

| CMS, Marketing, MCMG, Medicare | No Comments
The Centers for Medicare and Medicaid Services (CMS) typically issues a draft version of the Medicare Marketing Guidelines (MMG) early in the year for comment before releasing the final version…

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…

HHS Comes Full Circle: Section 1557 Regulations Again Interpreted to Prohibit Discrimination Based on Sexual Orientation and Gender Identity

| HHS | No Comments
On May 25, 2021, the Department of Health and Human Services (HHS) announced that it would again interpret and enforce the Section 1557 of the Affordable Care Act (Section 1557)…

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…

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…

Consultant Corner: Importance of Accurate Member Marketing Materials

| Consultant Corner, June 2023 | No Comments
Jill Pepe is a BluePeak Senior Consultant and Marketing Material Review Lead The Centers for Medicare and Medicaid Services (CMS) Annual bid process and timeline is one constant plan Sponsors…

CMS Announces Audits Targeting Fraud, Waste, and Abuse Beginning October 2022

| Audits, Fall 2022 | No Comments
Beginning October 2022 and continuing throughout 2023, CMS, in conjunction with the Plan Program Integrity Medicare Drug Integrity Contract (PPI MEDIC), will initiate three National Audits, six Self-Audits and four…

Interoperability Rule-This Could Be a Big Deal!

| CHIP, CMS, HHS, MA, MA-PD, QHP | No Comments
The Department of Health and Human Services (HHS) and Centers for Medicare & Medicaid Services (CMS) have published several new proposed and final rules on various topics, ranging from prescription…

Medicare Communications Marketing Guidelines: A Primary Topic at the CMS Fall Conference

| CMS, EOC, HPMS, Marketing, MCMG, Medicare | No Comments
BluePeak Highlights the Changes to MCMG Requirements The Centers for Medicare & Medicaid Services (CMS) 2018 Medicare & Prescription Drug Plan Fall Conference and Webcast kicked off on Thursday, September…

Part B Drug Timeliness Monitoring and Management

| CMS, ODAG, Part B, Uncategorized | No Comments
On May 23, 2019, the Centers for Medicare & Medicaid Services (CMS) published a final rule (CMS-4180-F) which adopted new processing timeframe requirements for preservice organization determinations and plan reconsiderations…

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…
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…

PACE Past Performance

| CMS, February 2023, PACE | No Comments
CMS continues to move PACE Organizations into alignment with Medicare Advantage plans, and use of past performance to inform request for new or expanded PACE programs is no exception.  While…

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…

Universe Monitoring Service Case Study and Service Spotlight

| CMS, IDS, Part C, Part D, UMS | No Comments
Many of the proposed audit protocol changes for both the 2020 and 2021 audit season included changes to universes. An incomplete and incorrect universe can add 1 point toward your…

BluePeak Podcast: Part D Benefit Changes on the Horizon and What does It Mean

| Part D, Podcast | No Comments
One of the biggest Part D changes revealed in the 2019 Call Letter was the closure of the Coverage Discount Gap Program a year earlier than scheduled. As a result,…

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…