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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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Understanding Non-Quantitative Treatment Limitations (NQTLs) and How BluePeak Advisors Can Help

| MHPAEA, NQTLs, Spring 2025 | No Comments
In the evolving landscape of healthcare coverage, ensuring parity between mental health/substance use disorder (MH/SUD) and medical/surgical (Med/Surg) services is crucial. The Mental Health Parity and Addiction Equity Act (MHPAEA)…

Medicare Part D Redesign: Navigating the Changes in 2025

| Medicare, Part D, Spring 2025 | No Comments
The Inflation Reduction Act (IRA) is poised to bring a significant transformation to the Medicare Part D benefit starting in 2025. This redesign will impact many stakeholders, including Part D…

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…

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…

Encounter Data – It’s Not Just Claims Data Anymore.

| CMS, Compliance, MA, Part C, Part D | No Comments
Background On September 14, 2020 CMS released The Advance Notice of Methodological Changes for Calendar Year (CY) 2022 for Medicare Advantage (MA) Capitation Rates and Part C and Part D…

Important: Opportunity for PACE Organizations to Comment on CMS Proposed Updates

| Uncategorized | No Comments
CMS has announced a 30-day comment period for the proposed collection entitled “The PACE Organization (PO) Monitoring and Audit Process” (CMS-10630; OMB control number: 0938–1327). This notice was published on…

ICYMI – BluePeak’s Articles posted recently on LinkedIn

| CMS, Medicaid, Medicare, PDE | No Comments
CMS Account Managers May Contact Plans to Assess New Medicare Card Project Readiness PDE Self-Audits Cost At Least One Plan Over $1 Million in Claims Reversals CMS to Conduct Provider…
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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…

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…

New Audit Protocols are Coming in 2021

| Audits, CDAG, CPE, FA, ODAG, SNP-MOC | No Comments
On December 6, 2019 CMS issued the HPMS Memo titled “Proposed Collection for New Medicare Part C and Part D Program Audit and Industry-Wide Part C Timeliness Monitoring Project (TMP)…

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…

CMS Releases Final Rule on Interoperability and Patient Access

| CMS, MA, Uncategorized | No Comments
On March 9, 2020, the Centers for Medicare & Medicaid Services (CMS) released the final rule (CMS-9115-F) regarding Interoperability and Patient Access. While CMS issued a fact sheet regarding this rule, this rule…

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: BluePeak discusses the impact…

Summary of CMS Changes to Enrollment Requirements for CY2021

| AEP, Enrollment | No Comments
Plans may have noticed that CMS has been busy this season making changes to certain Enrollment policies, materials, and software releases to keep up with the changing environment of today…

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…

Ready or not-the 2018 Audit Season is Upon Us…

| Uncategorized | No Comments
As Plans Continue to Struggle with the Same Common Conditions, CMS Makes Few Changes from the 2017 to 2018 Audit Protocols As the Centers for Medicare and Medicaid Services (CMS)…

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…

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…

The Model of Care Overhaul You Can’t Afford to Delay: Why 2025 Demands a Mock Audit Mindset

| Summer 2025 | No Comments
If your Model of Care (MOC) was written before 2025, it’s already outdated. With the release of the Centers for Medicare and Medicaid Services’ (CMS) draft MOC model documents, the…

Got Data?

| CMS, Data Reporting, IRE, Part C, Part D | No Comments
Independent Review Entity (IRE) Transparency Initiative Plans are continuously looking for data to better understand their appeals outcome.  The IRE transparency initiative provides plans with several more tools. During the…

Call Centers Beware

| CMS, Medicaid, Medicare | No Comments
On May 10, 2019, CMS published a final rule on Drug Pricing Transparency. The rule, effective July 9, 2019, requires direct-to-consumer television advertisements of prescription drugs and biological products payable…

BluePeak’s Definitive Guide to Preparing for 2020

| CMS, Marketing, MCMG, PDE, Training | No Comments
Bids were turned in the first Monday in June and now it is time to implement those benefits, plan designs and formularies that your organization has been hard at work…

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…

BluePeak Podcast: Initial Thoughts on CMS 2018 Spring Conference

| Podcast | No Comments
Tune into BluePeak’s newest podcast, to hear Principal Babette Edgar and Senior Consultant Susan Herman discuss their initial thoughts on last week’s CMS 2018 Medicare Advantage & Prescription Drug Plan Spring…

2024 Final Rule Changes: Impacts on Utilization Management Tools and Proposed Changes for 2025.

| CMS, December 2023, Utilization Management | No Comments
The Final Rule 2024 is one of the most substantive in recent years, with clarifications, codifications to existing rules and new requirements!  Plans need to be well prepared this year…

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…

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…

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:…

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…

Indication-Based Formulary Design in CY2020

| ANOC/EOC, CMS, FDA, HPMS, Medicaid, Medicare, Part D | No Comments
Beginning in the 2020 contract year (“CY2020”), the Centers for Medicare & Medicaid Services (“CMS”) will permit Part D sponsors to implement indication-based formulary designs that tailor formulary coverage of…

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…

CMS Continues Along Its Roadmap to Address the Opioid Epidemic

| Call Letter, CMS, DMP, Medicaid, Medicare, MME, Part C | No Comments
Effective January 1, 2019, the Centers for Medicaid & Medicare Services (CMS) required plan sponsors to implement new opioid policies as part of the agency’s continued efforts to address the…