Transition is highly scrutinized and frequently audited within the Medicare Part D program. For 2021, the Centers for Medicare & Medicaid Services (CMS) performed the Transition Requirements Analysis (TRA) to…
BluePeak AdvisorsDecember 17, 2021
Industry News
As we are begin the last quarter of 2021, Plans are thinking about readiness for January 1st. Below are just a couple of the areas that BluePeak suggests plans look…
BluePeak AdvisorsOctober 26, 2021
CMS Program Audit season is over and as anticipated, the volume of Program Audits increased substantially in 2021 over prior years. In addition, CMS introduced Part D self-audits which also…
BluePeak AdvisorsOctober 26, 2021
The Fourth Quarter is when most Plans work to finalize their risk assessment and their auditing and monitoring plan for the coming year. This is a good time to think…
BluePeak AdvisorsOctober 26, 2021
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…
BluePeak AdvisorsJuly 29, 2021
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…
BluePeak AdvisorsJuly 12, 2021
Now that bids have been submitted, it is time to start thinking about 2022 compliance and operations. One of the best ways to prepare for audit success and happy members…
BluePeak AdvisorsJune 11, 2021
With the 2021 Program Audit in full swing, CMS released the Program Audit Protocols for 2022 on May 26, 2021. The 2022 protocols are very similar to what was previously…
BluePeak AdvisorsJune 11, 2021
In addition to CMS performing numerous program audits thus far in 2021, recent memos have denoted that CMS is moving forward with several self-audits for plans to consider. In April,…
BluePeak AdvisorsJune 11, 2021
NEW! Beginning January 1, 2022, plans must send a written notice of dismissal for Part C OD and reconsideration requests as well as for Part D CD and redetermination requests…
BluePeak AdvisorsJune 11, 2021
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)…
BluePeak AdvisorsMay 26, 2021
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…
BluePeak AdvisorsMay 26, 2021
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…
BluePeak AdvisorsMay 12, 2021
Recent 1/3 Financial Audits have focused on the accuracy of billing of medications while a member is in a skilled nursing facility (SNF). Most drugs administered during an acute stay in…
BluePeak AdvisorsMarch 12, 2021
New COVID-19 Related Audit Considerations In addition to all of the other usual audit concerns, Plan Sponsors should also be prepared for CMS to scrutinize all things COVID-19 related. As…
BluePeak AdvisorsMarch 12, 2021
More Rigorous CMS Oversight and Audit Activity Ahead Audit notices are already hitting inboxes as CMS is kicking off a longer than usual Program Audit season this year (March through…
BluePeak AdvisorsMarch 12, 2021
Common Findings by Program Area In addition to ensuring compliance with COVID-19-driven changes, it is equally important to keep in mind lessons learned from prior audits when preparing for the…
BluePeak AdvisorsMarch 7, 2021
While CMS has been conducting audits for many years via webinar, the new reality is that many of the Plans being audited this season may have workforce at home. Following…
BluePeak AdvisorsMarch 5, 2021
Contract Year 2022 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicaid Program, Medicare Cost Plan Program, and Programs of All-Inclusive Care for the…
BluePeak AdvisorsMarch 5, 2021
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…
BluePeak AdvisorsJanuary 22, 2021
COVID-19 is having a dramatic impact on our lives, businesses and health care system. We understand that information and circumstances are changing rapidly and that many of your team members are…
BluePeak AdvisorsJanuary 19, 2021
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…
Amy DenihanJanuary 8, 2021
While compliance is a year-round expectation of the Centers for Medicare and Medicaid Services (CMS), plans are under even greater scrutiny by CMS and members alike at the beginning of…
BluePeak AdvisorsDecember 18, 2020
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…
BluePeak AdvisorsDecember 18, 2020
CMS released several interim and final rules in the past month. As the new year starts and there is a change in administration, the pace of new guidance releases is…
BluePeak AdvisorsDecember 18, 2020
Participation is expected to be strong in the Part D Senior Savings Model launch on 1/1/21 with 1,750 plans across 88 sponsors and 3 manufacturers participating in the program. Participating…
BluePeak AdvisorsDecember 18, 2020
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…
BluePeak AdvisorsDecember 18, 2020
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…
BluePeak AdvisorsNovember 24, 2020
The most effective way for any plan to avoid member disruption and compliance risks for the new plan year is to establish a process to validate the accuracy of the…
BluePeak AdvisorsNovember 24, 2020
As the date for compliance with the Interoperability Rule draws closer, BluePeak answers all of your questions, to help you stay in the know. 1 Question: I read the required…
BluePeak AdvisorsNovember 24, 2020
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