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, it is critical that Plans thoroughly review this checklist for insight into a shortlist of some of the requirements that CMS considers to be important for the upcoming year. Doing this allows Plans to have visibility into any areas that would require remediation for compliance as well as giving peace of mind that everything both internally and with delegated entities are in a ready state for the upcoming calendar year.
This year there are several things that CMS has encouraged Plans to pay specific attention to, such as attend user group calls, additional questions required on assessment screenings for Special Needs Plans (SNPs), attention to requirements regarding coordination of benefits (COB) , revisions to the Public Health Emergencies section with the end of the COVID pandemic, and the requirement for a Utilization Management Committee to name a few.
It is also noted that many items, while not new, have minor revisions or have been updated for 2024. This includes the addition of memo dates and CFR regulatory citations, similar to the format of the Medicare Communications and Marketing Guidelines.
What’s next?
To demonstrate readiness for 2024, Plans should consider implementing the following next steps:
- Plans should consider augmenting this list with other new 2024 requirements.
- Plans should assign a responsible party to each requirement on the Readiness Checklist.
TIP: Gather a group of key stakeholders to review the checklist and discuss.
- Plans should give responsible parties a reasonable amount of time to confirm their organization is either already compliant or will be compliant with each requirement by January 1, 2024. During this busy season it is important to ensure this request is appropriately prioritized.
TIP: It may help to have this “ask” originate directly from a Senior Plan Executive.
- Is your Plan compliant with each requirement?
- Yes: Require the assigned responsible party to: – Document evidence of compliance; and attest that the Plan is compliant with the requirement.
- No: Require the assigned responsible party to: – Document a Corrective Action Plan to bring the Plan into compliance with the requirement; Commit to a timeframe for achieving compliance with the requirement.
- Track any necessary Corrective Action Plans through to completion.
- Determine how and when to report anticipated non-compliance to the Plan’s CMS Account Manager.
- Anticipate your CMS Account Manager scheduling, prior to year-end, a strategic discussion about the Plan’s self-assessment of compliance and/or non-compliance with the requirements on the 2024 Readiness Checklist.
- Coordinate with your delegated entities to ensure they are prepared for CY 2024 set-up and testing of claims processing systems.
- Ensure all necessary enrollee materials, both print and electronic versions, have been updated to reflect changes that occurred under the Final Rule 2024.
Need Help to Ensure Your Plan is Ready for CY2024?
We can help complete your readiness review, perform operational assessments and/or mock audits of your Plan’s and delegates operations to detect areas requiring corrective action, help your Plan define and implement effective corrective actions where necessary, and assist your Plan with developing a prevention plan of ongoing monitoring and auditing to help minimize the ongoing risks of non-compliance.
Contact us today at (630) 694-5215 or email us at info@bluepeak.com.
