2016 CMS Application Season Begins
Yesterday CMS released the 2016 Part D application, and this afternoon the 2016 Medicare Advantage (MA) application was released. Despite the applications’ release dates, potential and current Plan Sponsors should be well under way in the preparation of the upload that is due on February 18th. Aspects of the application that require significant lead time to accomplish include the establishment of an adequate network and the acquisition of the required state licensure.
If you haven’t done so already, register for the industry user calls; these are scheduled to be recorded and available on the MSCG website a few days after each call. Today’s industry training was delivered by CMS’ Arianne Spaccarelli, Paul Foster, Nisha Sherry, Melissa Cooley and Greg Buglio. They provided an incredible amount of detail regarding the Part C application process, Special Needs Plans (SNP) proposals, and automated application training. It is worth listening to the recording, but here are some highlights:
Past performance will be considered — 14 month look-back. This was provided as a reminder in the past but this is in the regulation. See 422.502(b)(1-2) for the detail; boiled down, if during the past 14 months the MA organization fails to comply with the requirements of the Part C program under any current or prior contract, or in absence of 14 months of performance history, CMS may deny the application. You might be wondering if this is also outlined in the Part D regulations. It certainly is; in 423.503(b)(1-2) CMS also outlines the same for Part D organizations.
A major change that appeared in the draft 2016 MA application and made it to the final version was the deletion of the upload requirements for provider contract templates, executed administrative contracts/LOAs, and their respective crosswalks to regulations. This change reduces the burden to applicants in the short term. CMS stressed that attestations are still required to comply with these requirements and CMS may request that documentation at any time. (From our perspective, it is highly recommended that applicants consider incorporating the CMS-developed model contract amendment for MA administrative and management contracts, and for first tier or downstream entity provider contracts. You can find that on the MA applications site. Plans who do not use the model amendment may find themselves missing the spirit of the requirement if they do not include the exact required language. Worst case scenario? CMS comes a-calling, and picks apart your contracts. Why risk it? )
As in past years, there is an order to completing the steps of the application, and those steps have been outlined in the training. A number of inexcusable reasons for requesting an extension were described in delightful detail. They include trying to upload your provider and facility tables at the last minute, forgetting to hit the Final Submit button, or simply being unaware of your service area needs for your application. Listen to the call — they just aren’t having it!
Keep track of the GHG blog where I will provide some additional lessons learned from past applications, quirky issues that applicants often face, as well as important things to remember. Don’t go it alone if you can help it; many hands make light work with this type of project.
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The application process for Medicare Advantage and Part D, the Health Insurance Marketplace, and ACOs is an arduous one. Completing the application requires the cooperation from your entire organization.Don’t let the application process get in the way of your day-to-day operations. Contact us today to ensure a smooth, compliant process. Visit our website to learn more >>
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