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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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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…

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…

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…

CMS announced they will be performing a 2021 transition of care audit using the Transition Requirements Analysis (TR)

| Uncategorized | No Comments
CMS announced they will be performing a 2021 transition of care audit using the Transition Requirements Analysis (TR) that was piloted back in 2019.  Although the 2019 TRA did not…

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…

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,…

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…

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…

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…

Early Release of Medicare Advantage and Part D Advance Notice:  Part C & D Star Rating Changes

| MA, Part C, Part D, Star Ratings | No Comments
CMS published Part I of the Advance Notice of Methodological Changes for Calendar Year (CY) 2022 for Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies…

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…

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)…

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…

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…

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.…

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…

Step-by-step Guide to Developing an Effective Auditing and Monitoring Plan

| Audits, Compliance | No Comments
The Fourth Quarter is when most Plans work to finalize their risk assessment and their auditing and monitoring plan for the coming year. This is a good time to think…

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…

CMS Shifts Sales and Marketing Monitoring and Oversight to Plans

| CMS, CPE, CTM, Part D | No Comments
Executive Summary Since 2013, the Centers for Medicare & Medicaid Services (CMS) has steadily shifted direct monitoring and oversight of sales and marketing from the agency to plans. The removal…

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…

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…

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…

CMS Fraud Conference–Working Together to Combat Fraud

| CMS, FWA, Medicare, Part B, Part C, Part D | No Comments
From July 16-18th over 100 investigative minds met at the annual CMS Fraud Conference in Miami, Florida to talk about current fraud schemes, emerging schemes, data analytics and how to…

Universe Monitoring Service Case Study

| Case Studies, UMS | No Comments
Case Study During the course of a Medicare Program Audit the plan struggled with being able to generate accurate and compliant universes in a timely manner.  The plan had experienced…

Operational Impact of the Contract Year 2021 Final Rule

| COVID19, MA, SEPs, Star Ratings, SUPD | No Comments
Operational Impact of the Contract Year 2021 Final Rule On June 2, 2020 CMS released the Contract Year 2021 and 2022 Policy and Technical Changes to the Medicare Advantage Program,…

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…

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…

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…

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…

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…

CMS Increases Percentage of Encounter Data on Which MA Plans’ Payments are Based

| CMS, FWA, Part D, PDE, RAPS | No Comments
According to the Final Call Letter, the Centers for Medicare and Medicaid Services (CMS) will increase the percentage of encounter data, on which part of Medicare Advantage plans’ pay is…
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