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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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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…

The Centers for Medicare & Medicaid Services: 2024 Readiness Checklist for Medicare Advantage Organizations, Prescription Drug Plans

| CMS, December 2023 | No Comments
The Centers for Medicare & Medicaid Services (CMS) released the CY2024 Medicare Parts C and D Readiness Checklist on October 13, 2023. Although this is a busy time of year,…

Special Supplemental Benefits for the Chronically Ill: 2025 Proposed Rule Impacts to Consider

| CMS, December 2023, HHS, SSBCI | No Comments
Believe it or not, it is already time to start thinking about plan benefits for contract year 2025. Plan sponsors continue to look for ways to grow membership, modify benefit…

Is Your Part D Stars Program Ready to Ring in the New Year?

| December 2023, Opioids, Part D | No Comments
On April 12, 2023, Centers for Medicare & Medicaid Services (CMS) published the 2024 Final Rule that postponed moving the three polypharmacy measures (Concurrent Use of Opioids and Benzodiazepines, Polypharmacy…

Inflation Reduction Act (IRA): 2024 Summary of Changes and Oversight Considerations

| CMS, December 2023, IRA | No Comments
The Centers for Medicare & Medicaid Services (CMS) has released significant guidance to support the Inflation Reduction Act (IRA) provisions that impacts Medicare enrollees, health plans, pharmacy benefit managers (PBM)…

Consultant Corner: Strategic Planning: Using the Notice of Intent to Apply timing to trigger potential opportunities with your leadership and Board of Directors

| AEP, September 2023 | No Comments
Wendy Edwards, MPA, CHC, CHPC, is Director of Internal Operations at BluePeak Advisors, a division of Gallagher Benefit Services, Inc. Preparing for 2025 may not be at the top -of-mind…

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…

Changes to CMS Requirements for Translation and Alternate Formats

| FDR, MA, Part D, September 2023 | No Comments
To ensure effective communication and meaningful access, Medicare Advantage (MA) and Prescription Drug Plans (PDPs) have been obligated to follow various, occasionally interconnected directives for translating member documents into different…

2024 National Average Monthly Bid Amount Impact

| PBM, September 2023 | No Comments
On July 31, 2023, Centers for Medicare & Medicaid Services (CMS) released the National Average Monthly Bid Amount (NAMBA) for contract year (CY) 2024.  For 2024, the national average bid…

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)…

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…

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)…

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…

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…

BluePeak Releases Summaries and Webinar Covering 2019 Call Letter

| Call Letter | No Comments
Bluepeak Subject Matter Experts (SME) have reviewed the 2019 Call Letter and created the following for your reference. 2019 Call Letter Summary Detailed overview of this year’s changes and what…

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…

What are you doing to improve your Star Ratings?

| EHR, EMR, MPF, Part C, Part D, 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?…

What You Need to Know About Sections 504, 508 and 1557

| Compliance, Section 1557, Section 504, Section 508 | No Comments
You likely saw that CMS recently released a FAQ document on Section 504 and Section 1557. This FAQ document provides clarity on requirements that several organizations have been questioning since…

BluePeak Podcast: Cost of Non-Compliance

| CMPs, CMS, Podcast | No Comments
The Facts are Sobering: CMPs may be the least expensive part of being non-compliant. CMS audits are on the rise, as are CMPs and sanctions. The average CMP is around…

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…
Hand holding a sparkler

New Year’s Day is Ultimate Test of New Part D Plan Year Readiness

| Audits, CDAG, CTM, FAA, PBM, TPMA | No Comments
While most people are singing Auld Lang Sine at midnight on January 1, those of us in the Medicare world are anxiously awaiting the first claims of the plan year…

Accurate Call Classification and Handling-Strategies for Evaluating and Monitoring Your Customer Service Team

| Audits, Call Log Review, CMS, Part C, Part D, Star Ratings | 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…

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…

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…

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…

NEWS ALERT – 12/27/2022

| News Alert | No Comments
BluePeak’s releases index on the entire proposed rule contents December 27, 2022, CMS published proposed rule CMS FRDOC 001 regarding Medicare Program; Contract Year 2024 Policy and Technical Changes to…

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…

The 2019 CMS Program Audit Season is Upon Us!

| Audits, CDAG, CMS, CPE, FA, ODAG, SARAG, SNP-MOC | No Comments
CMS started issuing audit letters in March and will continue doing so through July. If you haven't already received an audit notice, what are you doing to prepare? 2019 starts…

Inflation Reduction Act (IRA): 2024 Summary of Changes and Oversight Considerations

| CMS, December 2023, IRA | No Comments
The Centers for Medicare & Medicaid Services (CMS) has released significant guidance to support the Inflation Reduction Act (IRA) provisions that impacts Medicare enrollees, health plans, pharmacy benefit managers (PBM)…

Service Spotlight: Comprehensive Support from Bid to AEP and Beyond…

| AEP, MCMG, Member Materials, Part D | No Comments
On February 9, 2022 CMS released the Medicare Advantage and Part D Communications & Marketing Guidelines (MCMG) reminding us all of what we already know- it’s time to begin planning…

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…

Changes to CMS Requirements for Translation and Alternate Formats

| FDR, MA, Part D, September 2023 | No Comments
To ensure effective communication and meaningful access, Medicare Advantage (MA) and Prescription Drug Plans (PDPs) have been obligated to follow various, occasionally interconnected directives for translating member documents into different…

Highlights of CMS-Proposed Changes in Draft 2019 Call Letter

| CMS, CPE, Part C, Part D | No Comments
The Centers for Medicare and Medicaid Services (CMS) proposes changes to Star Ratings, validation audits, annual Compliance Program Effectiveness (CPE) audits, Part D opioid overutilization policy, and more in the…

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…

BluePeak Service Spotlight: Mock Audits with UMS and Call Log Reviews

| Call Log Review, CMS, UMS | No Comments
BluePeak has conducted over 150 CMS mock audits and onsite support projects for clients undergoing actual CMS program audits. We also offer mock audit breakouts, such as our Universe Monitoring…

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…

OIG finds MAOs Inappropriately Denying Requests for PA and Payment, CMS agrees to Issue Stricter Guidance and update Audit Protocols and Auditor Training

| CMS | 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…

Contract Year 2021 Monitoring of Posted Comprehensive Formularies

| Audits, CMS | No Comments
On November 2, 2020, CMS released the results of the CY2020 Monitoring of Posted Comprehensive Formularies or their Posted versus Approved (PvA) analysis.  For the CY2020 analysis, CMS announced that…

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…
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