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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…

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…

Using Interim Staffing to bring Appeals and Grievances Timeliness into Compliance–A Case Study

| Compliance, IRE, MA, MA-PD, Part D, PBM | No Comments
Sometimes, life happens. Turnover, volume increases, changing guidance, system changes or audit issues that require remediation all can create situations where a Plan or PBM needs expert resources fast.  And…

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…

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…

2025 Audit Insights: Elevating Call Center Performance with FCR and QOC Grievance Management

| Summer 2025 | No Comments
Member service representatives are the heart of a health plan.  Their engagement with members significantly influences a member's perceived experience with the plan and their care journey.  For a Medicare…

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…

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…

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…

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…

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…

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…

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…

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…

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…

BluePeak Service Spotlight: Universe Monitoring Service

| Audits, CMS | No Comments
On February 8, 2019, CMS released “CMS Program Audits Frequently Asked Questions (FAQs).  One of the questions addressed  was: “Will sponsoring organizations always have the opportunity to submit universes up…

CMS Discusses Draft 2019 Audit Protocols and More at Conferences

| Audits, CMS, Uncategorized | No Comments
BluePeak Lists Top 5 Changes by Impact to Plan Sponsors Following a flurry of final and proposed rulemaking in April, the Centers for Medicare and Medicaid Services (CMS) discussed program…

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…

New Fraud Schemes

| Fraud, NHCAA | No Comments
In October, the National Health Care Anti-Fraud Association (NHCAA) held its annual training conference that spotlighted emerging fraud schemes. In addition to updates on the brace, genetic testing, and foot…

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…

BluePeak Services Spotlight: End-to-End Part C Claims Processing and Part D Claims Testing and Monitoring

| CMPs, CMS, Part C, Part D, Uncategorized | No Comments
In addition to the Centers for Medicare & Medicaid Services (CMS) program audits, a plan’s claims issues, such as not processing Low-Income Subsidies (LIS) correctly, can surface in one-third financial…

CMS Expands Penalties in 2017

| CMPs, CMS, Medicare, Part C, Part D, PBM | No Comments
One-Third Financial Audit Findings Will Cost You More This Year The Centers for Medicare & Medicaid Services (CMS) is now considering deficiencies found from one-third financial audits for potential enforcement…

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…

2019 Program Audits Reflect Continued Improvement

| Audits | No Comments
Reprinted with AIS Health permission from the October 1, 2020, issue of RADAR on Medicare Advantage CMS’s latest overview of program audits showed continued improvement among Medicare Advantage and Part…

Big Changes Ahead for Group Health Plans and Individual Health Plans

| Legal, Summaries | No Comments
The following are summaries of Rules that contain big changes for group health plans and individual health plans. SummaryInterim Final Rule with Comment Period Requirements Related to Surprise Billing; Part…

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…

Civil Money Penalty Rates Increasing

| CMPs | No Comments
On April 8, 2022, CMS released the updates to the standard Civil Money Penalty (CMP) amounts that will be used for the next three years beginning with plan year 2022. …

Is Your Plan Ready for the New Year?

| CMS, MBI, Medicare, Open Enrollment, Part D | No Comments
Annual Notices of Changes (ANOC) shared with enrollees Evidence of Coverage (EOC) shared with enrollees Formulary shared with enrollees Pharmacy and Provider Directories shared with enrollees Medicare Communications Marketing Guidelines…

Provider Directory Accuracy Monitoring and Use of the National Plan & Provider Enumeration System (NPPES)

| CMS, Part C, Part D | No Comments
On March 11, 2020 the CMS Part C and D User Call focused on Provider Directory accuracy and how the NPPES may support such accuracy.  In case you missed it,…

Top 10 Audit Tips

| Audits, CMS, Tips | No Comments
Here are some tips to help ensure your Plan is adequately prepared as audit season gets underway for 2021. Ensure your plan and all of its delegates can produce accurate…

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…