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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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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…

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…

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…

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…

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…

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 PDE Submission Deadline is Rapidly Approaching-Don’t Assume a High Acceptance Rate Translates to PDE Accuracy

| CMS, Compliance, PBM, PDE | No Comments
The 2021 PDE submission deadline is June 29, 2022.  Plans must attest to the accuracy of their submitted PDE records prior to CMS’ financial reconciliation.  The challenge is that many…

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: Claim Accuracy is More…

It is Always a Good Time to Think About Star Ratings

| HEDIS, MPF, Star Ratings | No Comments
As you checked your plan data that will be displayed on Medicare Plan Finder (MPF) for accuracy during the recent second plan preview, were you happy with your Star Ratings?…

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…

CMS Placing More Scrutiny on MTM

| CMS, MTM | No Comments
Hot Topic MTM has become a popular topic with CMS not only at their Spring conference but also as a new pilot for their Program Audits.   CMS is placing more…

ICYMI – BluePeak’s Articles Posted Recently On LinkedIn

| LinkedIn, Uncategorized | 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: Audit Tip #3-- It’s…

Part D Operational Implications of the Inflation Reduction Act (IRA) of 2022

| IRA, November 2022 | No Comments
On August 16th, the Inflation Reduction Act of 2022 (IRA) was signed into law.  The text of the bill is located here and includes changes that, among other things, would…

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…

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,…

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…

Benefits of a Compliance Program Effectiveness Audit– Going Beyond Just Meeting the Requirement

| Audits, CMS, CPE | No Comments
CMS guidance requires Medicare Advantage Plans to have an independent audit of their compliance program’s effectiveness each year.  Given competing priorities, it may be tempting to conduct a limited or…

ICYMI – BluePeak’s Articles Posted Recently On LinkedIn

| Ask the Expert, LinkedIn | No Comments
BluePeak's Summary on COVID-19 Gallagher Special Olympic partnership COVID-19 Medicare Fact Sheet 10 Things Plan need to know about the Proposed Rule   Kelly MaKay, RPh, MBA Senior Health Plan Services…

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,…

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…

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…

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…

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…
prescription pills

Opioid Epidemic Spotlights Health Plans’ FWA Investigations

| CDAG, CMS, CPE, FDRs, PBM | No Comments
On October 26, President Donald Trump declared the nation’s opioid epidemic a public health emergency. The opioid epidemic is the deadliest drug epidemic in American history.  Deaths from opioid overdose…

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…

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…

Significant Changes Proposed for Qualified Health Plans

| ACA, CMS, CSR, FFE | No Comments
The Centers for Medicare & Medicaid Services (CMS) recently released a proposed rule titled “Patient Protection and Affordable Care Act; Updating Payment Parameters, Section 1332 Waiver Implementing Regulations, and Improving…

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 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…

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. …

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…
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