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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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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…

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…

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,…

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…
Street signs one stating 2018 and pointing left, the other stating 2019 and pointing right

Getting Ready for Early Application Tasks and Understanding 2019 Application Changes

| CMS, HPMS, Medicare, Uncategorized | No Comments
Submit Notice of Intent to Apply (NOIA) Now Each year, the Centers for Medicare and Medicaid Services (CMS) accepts applications from new plan sponsors, as well as existing Medicare Advantage-Prescription…

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…

97% Isn’t Good Enough: Why Every Decision Matters

| Fall 2022, ODAG | No Comments
The Organization Determinations, Appeal and Grievances (ODAG) area of a Centers for Medicare & Medicaid Services (CMS) Program Audit focuses on high-risk areas with the greatest potential for enrollee harm. …

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…

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…

ICYMI – BluePeak’s Articles posted recently on LinkedIn

| LinkedIn | No Comments
BPA Connection Matches Healthcare Job Seekers and Employers - https://www.linkedin.com/feed/update/urn:li:activity:6380517376378564608 BluePeak’s End-to-End Part C Claims Processing Audit Finds Deficiencies BEFORE CMS Does - https://www.linkedin.com/feed/update/urn:li:activity:6381527793406083073 BluePeak Shares “2019 Final Call Letter…

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.…

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…

What should plans do when COVID-19 impacts provider response times to standard and expedited appeals?

| COVID19 | No Comments
Plans have speculated that CMS might relax  the standard and expedited Appeals timeframes to allow more time for prescribers to respond since a large portion of prescriber’s offices are on…

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…

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…
finger on a map

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…

BluePeak Service Spotlight: Member Material Review

| CMS, EOBs | No Comments
BluePeak’s consultants have experience reviewing member materials from their work at Plans and for the Centers for Medicare and Medicaid Services (CMS). We can help you populate and/or review the…

Another Symptom of COVID-19-Fraud

| COVID19 | No Comments
CMS issued a Fraud Alert on COVID-19 schemes on March 23 and additional guidance was released via HPMS on April 1st.  On April 16th, the National Health Care Fraud Anti-Fraud…

Why Medical Claims Audits?

| Claims, Medicare | No Comments
In view of ever rising benefit costs, employers and Medicare Advantage plans should consider a medical claims audit as part of an overall benefits and cost-containment strategy.  Medical claims audits…

Biden Administration Immediate Actions May Affect Health Plans

| Uncategorized | No Comments
President Biden hit the ground running, signing a batch of Executive Orders just hours after he was sworn in as the 46th President of the United States.  A couple of…

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…

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…

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…

‘Tis ALWAYS the season….for rejected claims analysis.

| CMS, PBM | No Comments
As year-end approaches, most plans are conducting claims testing to ensure that formularies and benefits are administered correctly on January 1 and beyond.  Plans and PBMs alike that have experienced…

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…

Question & Answer

| Legal, PBM | No Comments
Q: Is it permissible for the Compliance Officer to report to General Counsel or the Legal Department?  A: While some Plans and PBMs do this, it is not ideal or…

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…

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…

BluePeak’s Summary of the September 2018 Medicare Communications and Marketing Guidelines (MCMG)

| CMS, Marketing, MCMG | No Comments
On July 20, 2018, the Centers for Medicare & Medicaid Services (“CMS”) released the Medicare Communications and Marketing Guidelines (“MCMG”), replacing the Medicare Marketing Guidelines and all associated guidance in…

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?…

Potential Changes on the Horizon for 2020 and Beyond

| CMS, FDRs, HPMS, Medicaid, Medicare, Star Ratings, TPMA | No Comments
After getting ready for all the changes a new contract year brings, Medicare Advantage (MA) Plans and Part D sponsors await the issuance of the Draft Call Letter for early…
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