12 Years in the Making - Rules Guiding Medicaid Managed Care are Getting a Makeover
At the Medicaid Health Plans of America (MHPA) meeting last week in Washington, DC, there was a lot of buzz surrounding the upcoming release of an updated Medicaid Managed Care regulation. Per CMS officials speaking at the conference, the last update was 12 years ago!
Discussions surrounding the update were focused on three main themes:
- Aligning Medicaid Managed Care with other public programs
- Payment and accountability
- Network adequacy
Aligning with other programs — This could take many different shapes and sizes. Certainly the well-established program guidelines of Medicare Advantage could become very prominent. In contrast, the newly evolving rules of the Exchange Marketplace could be drawn more into the spotlight. Being that Medicaid beneficiaries sometimes align with Medicare Advantage and sometimes with Exchanges, this is likely to draw a lot of comments from the industry when released in the coming months.
Regardless of how you think it should be done, the rationale to better align all of these programs makes good sense for both beneficiaries and the managed care plans that serve them. Beneficiaries can have common experiences; families with multiple program enrollments have an easier time navigating the system; and plans reduce unnecessary administrative burden to administer multiple programs.
Payment and accountability — Several hot button items are involved in this theme. All of these involve modernizing the regulation to the current day environment.
- Using data to think about issues related to rate setting and rate review
- Using program dollars wisely, as more is at stake as the program continues to evolve and grow
- Integration of long-term services and supports into the regulation
Network adequacy — The OIG recently released a report identifying significant variation between states as it relates to access to care, and how those standards are being checked on a regular basis. With the recent significant growth in Medicaid Managed Care enrollment, this becomes even more concerning. We can expect CMS to take a strong stance on access to care issues including network composition, availability of primary care and specialists, and provider directory issues. As a major beneficiary protection issue, we also expect this area to draw a lot of comments from the beneficiary community.
We are very anxious to see the draft regulation and the "give and take" it is going to provide to the industry. With 12 years worth of ideas baked into it, it should be a fun ride!
Resouces
Gorman Health Group, LLC (GHG), the leading consulting firm and solutions provider in government health care programs, announced its further expansion into Medicaid, and the promotion of one of the nation's leading Medicaid experts, Heidi Arndt, to lead the division. Read more >>
Gorman Health Group is dedicated to assisting managed care organizations, as well as states with developing models of care, maximize member engagement. Visit our website to learn more about how we can help you with your Medicaid initiatives.
Save the Date for the Gorman Health Group 2015 Forum. Join us April 7-9, 2015 at the Gaylord National Resort and Convention Center in National Harbor, MD. Learn more about the event >>
Little Reason for Optimism in Red State Medicaid Expansion
For months several Wall Street analysts and others have predicted near-total adoption of the Affordable Care Act's Medicaid expansion by the states. To date, only 27 have, and I see little optimism for more than a handful to do so anytime soon.
Red State governors are WAY more entrenched than anyone anticipated, and they're getting too much political mileage out of throwing a middle finger at the guy in the White House to stop. Even if Democratic candidates leading in states like Florida win next week, the barrier is often their state legislatures. Virginia is a great example of a pro-expansion Democrat thwarted by his state lawmakers -- one that will be repeated many times in 2015.
Last week we heard mixed news on Medicaid expansion: it appeared likely that Utah governor Mike Herbert would accept an Arkansas-style expansion in a rare compromise with the Obama Administration, and also pretty certain that Indiana governor and 2016 GOP Presidential possible Mike Pence would reject one. Even if Herbert takes the deal, Utah may be another example like Virginia, with a supportive governor blocked from expanding by his state house.
At least six states could adopt Medicaid expansion, including Florida, Georgia, Kansas, Maine, Wisconsin and Alaska, if -- and it's a huge if given the political headwinds -- Democrats and one independent candidate win their gubernatorial races. The obstacle is getting state lawmakers on board in Florida, Georgia, Wisconsin and Kansas, where Republicans control the legislature.
So maybe it's really just Maine and Alaska that have any real shot at expansion? Maine lawmakers are poised to expand Medicaid if Tea Party wingnut Governor Paul LePage is defeated next week. LePage has vetoed several bills to expand the program after they were passed by the Democrat-controlled Maine legislature, and he is trailing in the latest polls. Alaska isn't nearly as far along.
A handful of new Republican governors could move for expansion, albeit after the midterm elections. Tennessee GOP Governor Bill Haslam said he plans to submit a plan later this year, although state Republican leaders warn it will be difficult to win approval. Wyoming Governor Matt Mead, also a Republican, said he will present an expansion plan to his legislature early next year, but prospects also seem slim there.
In many of the remaining Red States, where uninsurance is most epidemic and the ACA is needed most, there seems to be little hope of elected officials actually doing their jobs and meeting the needs of their constituents:
- In Mississippi, expansion doesn't have a snowball's chance in Hell. GOP Governor Gary Bryant made it clear Mississippi would not participate, leaving 138,000 residents, the majority of whom are black, with no insurance options at all after infighting killed the state's embryonic health insurance exchange.
- In South Carolina, where expanding Medicaid could reduce the number of people without health insurance by one-third, the state's health plan association doesn't expect any movement until at least 2017. Even its state medical association won't back expansion, apparently preferring bad debt and fewer customers to Medicaid payment.
- In Louisiana, payers aren't hostile to expansion, they just don't see any point in pushing it. The state health plan association chief said "it's a state where both the House and the Senate, and the governor, are pretty much on the same page of not being interested in moving toward expansion this year or next year."
- In Alabama, even the state's health plan association is openly opposed to expansion. "I agree, and I think my members agree, that [Governor Robert] Bentley is doing the right thing" by saying no, the association CEO said. In its current form, "expanding Medicaid makes zero sense for Alabama."
- In Texas, which has more uninsured people than Colorado has people? Um, no.
With Republicans poised to retake the US Senate next week and expand their dominance in the House, all this hopeful chatter about Medicaid expansion seems more like liberal dreaming than reality. Maybe 2-3 more states in the next two years, if we're lucky.
Resources
Gorman Health Group, LLC (GHG), the leading consulting firm and solutions provider in government health care programs, announced its further expansion into Medicaid, and the promotion of one of the nation's leading Medicaid experts, Heidi Arndt, to lead the division. Read more >>
GHG is dedicated to assisting managed care organizations, as well as states with developing models of care, maximize member engagement. Visit our website to learn more >>
Save the Date for the Gorman Health Group 2015 Forum. Join us April 7-9, 2015 at the Gaylord National Resort and Convention Center in National Harbor, MD. Learn more about the event >>
The Good, the Bad and the Ugly in Medicare Advantage
In the last two weeks there's been good, bad and ugly news for Medicare Advantage (MA) plans. On one hand, the program has never been stronger and quality metrics are surging in the right direction; on the other, the industry is sucking it up on following the rules of its biggest customer, the Centers for Medicare and Medicaid Services (CMS).
First, the good: CMS did its annual data dump on Medicare Advantage and Part D bids and showed the program continuing its robust growth, with higher-than-ever enrollment approaching 17 million, and plans holding premiums and benefits steady during the worst rate environment in decades. Then, CMS released the MA Star Ratings database for 2015, showing MA quality continues to improve. The enrollment-weighted Average Star Rating for the industry stands at 3.91 out of 5. 40% of MA contracts were awarded 4+ Stars for 2015, but 60% of enrollees are members of those plans, showing a 30% increase since 2012 and demonstrating the competitive advantage high-performing plans now enjoy. The 2015 ratings show stable or improved performance in almost 70% of the 46 Part C & D Star measures, 7 of which improved by more than one-half star from 2014 to 2015, and 13 of which earned average ratings above 4 stars in 2015. There was even an 85% decline in plans receiving the low-quality performance badge of shame.
But then the bad: it's clear plans have eaten low-hanging Star fruit and are starting to struggle on more complex and outcomes measures, such as managing chronic conditions, managing mental health to improve outcomes, or increasing physical activity and reducing fall risk. The longitudinal Health of Seniors survey scores are below 3 Stars, and 135 plans remain on the Quality Bonus Payment bubble at 3.5 stars in 2015, meaning almost half of MA plans are circling the financial toilet bowl. Not good.
And then the ugly: last week's blistering New York Times story on rampant noncompliance among MA plans. The Times combed through months of compliance action reports and found widespread failures by plans in administering the program, including some common and potentially life-threatening stumbles:
- In more than half of all audits, "beneficiaries and providers did not receive an adequate or accurate rationale for the denial" of coverage when insurers refused to provide or pay for care.
- When making decisions, insurers often failed to consider clinical information provided by doctors and failed to inform patients of their appeal rights.
- In 61% of audits, insurers "inappropriately rejected claims" for prescription drugs. Insurers enforced "unapproved quantity limits" and required patients to get permission before filling prescriptions when such "prior authorization" was not allowed.
- MA plans frequently missed deadlines for making decisions about coverage of medical care, drugs and devices requested by doctors and patients.
CMS officials expressed frustration that they were seeing the same deficiencies year after year. That these boneheaded infractions are often being repeated makes the news all the more depressing. It's important to remember if an MA plan with a Star Rating over 3.5 gets sanctioned by CMS for noncompliance, it automatically knocks its rating down to 2.5. That's a kiss of death for an otherwise quality company.
What the Stars and compliance data show us is that the plans are doing great on strategy, pricing their benefit designs, selling to Baby Boomers, and managing straightforward quality process measures. But looking closer, it also shows our industry has a serious execution problem. We are lagging on performance measures with multiple clinical moving parts, and embarrassing ourselves and endangering our companies and beneficiaries with "101-level" compliance errors.
With both Federal and state governments increasingly relying on MA plans to manage the most complex and expensive patients in the US health system, we can and must do better.
Resources
Listen as John Gorman provides several takeaways from our first review of the terabytes of CMS data and understand why he believes this data shows the triumph of government-sponsored programs. Access the podcast here >>
Gorman Health Group can evaluate your Star Ratings approach and identify tactics you can begin implementing immediately to integrate initiatives, eliminate redundancies, and build an enterprise-wide Star management structure. Visit our website to learn more >>
Save the Date for the Gorman Health Group 2015 Forum. Join us April 7-9, 2015 at the Gaylord National Resort and Convention Center in National Harbor, MD. Learn more about the event >>
NY Times article reiterates compliance trends in Medicare Advantage
As many of you have already read, the NY Times ran a scathing article on October 12th titled "U.S. Finds Many Errors in Medicare Health Plans" shining a light on serious Compliance issues we've all been aware of over the past several years. Is the continued lack of non-compliance really news to anyone in the industry? Most certainly not — we have all been tracking the continued issues of non-compliance, increased CMS Compliance actions, and have read the audit reports posted on the CMS website. What the NY Times article did was remind us that the compliance trends in Medicare Advantage are a serious matter which should not be taken lightly.
The fact is, Medicare beneficiaries have not had access to their care; both Medical care and Prescription drugs.This is simply not acceptable — period. That being said, I have personally worked on the Plan side, on the consulting side, and as a CMS sub-contractor, and I know, firsthand, the challenges we face in the implementation of the thousands of Compliance requirements. This is no easy task, and anyone who thinks it is, simply doesn't understand plan operations. By and large, what we find is that Organizations want to be compliant; but they don't have the tools or resources to implement and manage this highly regulated program. So, what do you do next? Here is what we recommend:
- If you haven't done so already, go through the exercise of a Mock CMS audit - find your deficiencies now, both for the sake of the beneficiary, and for the sake of your CMS contract.
- Focus first on those issues that have the most beneficiary impact — ensure that your members have access to care as your number one priority.
- Document your remediation efforts and measure outcomes — issues aren't resolved overnight, but ensuring that your remediation plan is working is the key to success.
If you're not sure where to start, we can help. Please find here a description of our Mock CMS Audit Service, or contact us directly.
Resources
On Friday, Sept, 12 a GHG team member provided GHG's perspective on trends relating to CMPs, the CMS audit findings and oversight activities that have taken place in the last six to 12 months, as well as tips on how to avoid and remediate CMS findings. Become a member of the Point to access the webinar recording >>
All Medicare Advantage and Prescription Drug Plans must ensure that they are audit-ready all the time so that each CMS audit is routine. Save the fire drills for fires, and receive standing ovations for the organization's final performance. Visit our website to learn more >>
Save the Date for the Gorman Health Group 2015 Forum. Join us April 7-9, 2015 at the Gaylord National Resort and Convention Center in National Harbor, MD. Learn more about the event >>
Exchange 2014 Data Submission Due April 30,2015
As we wind down on our inaugural year with Health Insurance Exchanges (HIX), we have seen plans using a variety of approaches in their Risk Adjustment data reporting efforts. Some continue to use the same approaches used for their Medicare programs (chart reviews, provider outreach, in-home assessments, etc). Some have not even begun any retrospective, prospective or quality programs because they don't know where to begin. What is the right approach? Probably somewhere in the middle.
Qualified Health Plans need to be very targeted in their retrospective and prospective programs. They also need to have some type of quality assurance program in place. Although HHS has stated that "For 2014 and 2015, an initial and second validation audit will be conducted, but the findings will not be used to adjust payments." Plans still need to be cognizant of the quality of the data they are submitting and are still subject to the False Claims Act. CMS has also stated that when medical record reviews are performed, "the issuer must evaluate all diagnoses on the original claim and the issuer must delete any diagnoses not supported by the medical record." This is a new practice for many plans, but one that must be implemented.
Whether you rely on multiple vendors, an internal team, or a combination of the two, GHG can help you streamline the execution of your risk adjustment approach, and build a roadmap to ensure you're keeping stride with HHS expectations in both compliance and health care outcomes. Our services include:
- Risk Adjustment Strategies — Retrospective, Prospective and Concurrent Outreach strategies, evaluation of staffing structure and levels
- Quality Assurance Programs — Proactive programs to improve data accuracy
- Data Analytics — Identifying data gaps and appropriate gap closures
- End to End Process Review — Testing for dropped data and recommendations for best practices in data processing
- Provider Education/Coding - including ICD 10
- Risk Mitigation - Identifying unsubstantiated diagnosis codes
- Data Validation — Mock Audits
- Vendor Audits — Coding accuracy, data completeness
- Requests for Proposals (RFP) - Developing RFPs and/or the evaluation of RFP vendor responses
Resources
In a webinar on Thursday, October 23, Janet Fina, GHG's Vice President of Risk Adjustment, together with colleague, Carol Olson, GHG's Director of Risk Adjustment, addressed areas for documentation improvement that will allow for accurate reimbursement and disease and case management opportunities. Become a member of the Point to access the recording >>
Gorman Health Group supports our clients in evaluating the efficiency, compliance, and strategic value of their risk adjustment programs from start to finish, and helps ensure that the procedures for capturing, processing and submitting risk adjustment data to CMS are accurate, timely, and complete. Visit our website to learn more >>
Save the Date for the Gorman Health Group 2015 Forum. Join us April 7-9, 2015 at the Gaylord National Resort and Convention Center in National Harbor, MD. Learn more about the event >>
Noteworthy declines in Star Measures: Ensure a 4-Star Performance
With 5% of revenue contingent on achieving at least 4 Stars, the stakes have never been higher for Medicare Advantage plans. Within the 40% of plans earning at least 4 Stars in 2015, plan leaders are celebrating their return on investment from quality improvement initiatives and other Stars-impactful activities. But for the 135 plans on the Stars bubble at 3.5 Stars, and the 102 plans earning 3 or fewer Stars in 2015, the race is on.
Although performance continued to improve on most screening measures and on measures within the plans' control in 2015, ratings declined on 15 of the 46 Star measures in 2015. The most noteworthy declines occurred on the following measures, all of which require significant coordination across provider , and pharmacy networks, plan personnel and members:
- Three of five diabetes care management measures (with two measures dropping by more than one-quarter star each, and declines on both of the triple-weighted Part C intermediate outcomes measures associated with diabetes),
- All three triple-weighted medication adherence measures and the high risk medication measure,
- Care coordination and customer service measures.
In addition, four additional measures, which are heavily dependent on effective care coordination as well as member education, continue to perform under 3 Stars:
- Improving or maintaining mental health,
- Special needs plan care management,
- Improving bladder control,
- Osteoporosis management in women who have had a fracture.
Since enrollment in high performing plans continues to grow, and dramatic improvements have occurred in low-performing plans, CMS is likely to continue driving quality and accountability of physicians, hospitals, and other providers through the ever-evolving Medicare Advantage Star Ratings program.
As plans race into the unavoidable 4th quarter ‘Stars crunch,' now is an ideal time to ensure that adequate workplans, budgets and resources are available to enable 4 Star performance. If your plan is striving to achieve 4 Stars, Gorman Health Group is ready to help! From evaluating organizational strategy to developing and optimizing tactical Star ratings workplans, our team of experts has a long history of success helping health plans achieve Star ratings success.
Resources
Gorman Health Group can evaluate your Star Ratings approach and identify tactics you can begin implementing immediately to integrate initiatives, eliminate redundancies, and build an enterprise-wide Star management structure. We can help you identify clinical, operational, and networking opportunities to increase your score for 2016 and beyond. Visit our website to learn more >>
Save the Date for the Gorman Health Group 2015 Forum. Join us April 7-9, 2015 at the Gaylord National Resort and Convention Center in National Harbor, MD. Learn more about the event >>
Reversing the Trend: Improving Care Coordination
The good news from the 2015 Star Ratings is clear: Medicare Advantage plans held steady or improved in almost 70% of the 46 Part C & D Star measures. But the more subtle message hidden underneath the 15 measures where performance declined in 2015 is similarly clear: health plans have not yet mastered population management and care coordination in a way that improves health outcomes. By linking the Quality Bonus Payments to 4 Star performance, the Centers for Medicare & Medicaid Services (CMS) is conveying their message: health plans must effectively coordinate the diagnosis to the healthcare activities for their members in order to drive improved health outcomes and satisfy members.
Gorman Health Group is often asked how plans can achieve Star Ratings success. As 2015 draws to a close, the following are a few key near-term suggestions on which to focus in order to achieve Star Ratings success in 2016:
- Create (or review) 2016 Stars work plan(s), evaluate customer service and medical/case management work streams, and processes to identify areas for improved care coordination.
- Evaluate provider and pharmacy network strategy to ensure that infrastructure supports Stars goals.
- Evaluate Stars performance among provider and pharmacy networks and develop targeted activities with under-performers.
Our team of experts can help you develop or enhance care coordination within your programs and processes. Contact us today, and let's work together to help your plan achieve 4 Stars.
Resources
Gorman Health Group can evaluate your Star Ratings approach and identify tactics you can begin implementing immediately to integrate initiatives, eliminate redundancies, and build an enterprise-wide Star management structure. We can help you identify clinical, operational, and networking opportunities to increase your score for 2016 and beyond. Visit our website to learn more >>
Save the Date for the Gorman Health Group 2015 Forum. Join us April 7-9, 2015 at the Gaylord National Resort and Convention Center in National Harbor, MD. Learn more about the event >>
They Still Don't Like It
In the October 8, 2014 memo entitled "Contract Year 2014 Part D Formulary Administration Analysis (FAA)", CMS reiterates their concern with the accuracy of formulary coding. For the April 2013 analysis, 9 out of 88 (10.2 %) plan sponsors were found to have failed FAA, meaning that greater than 20% of the sampled rejects were determined to be inappropriate. The parameters for the 2014 FAA are:
- Sponsors will be required to submit all point-of-sale (POS) rejected claims relating to the following 4 categories: 1) non-formulary status; 2) Prior Authorization (PA); 3) Step Therapy (ST); and 4) Quantity Limits (QL).
- Larger plans (≥ 20,000 enrollees) should submit rejected claims data for service dates of June 1, 2014 through June 14, 2014 and smaller plans (< 20,000 enrollees) should submit rejected claims data for service dates of June 1, 2014 through June 30, 2014.
If you were one of the plans selected for the FAA, you were required to upload files to the Acumen site between October 16 and October 22. CMS will then select a sampling of the rejected claims for review. Those plan sponsors who meet or exceed the failure threshold will receive a notice of non-compliance and depending on how badly the plan sponsor exceeds the failure threshold, additional sampling and compliance actions may result.
Not to beat a dead horse, but this should again remind us of the importance of formulary benefit administration testing---rigorous and extensive at the beginning of the plan year and at every point during the plan year when formulary changes are made. You can't afford NOT to.
Resources
Beneficiaries should be able to receive the Part D drugs they are entitled to, consistent with CMS guidance, from January 1st through December 31st of the plan year.
We can help your MAPD or PDP develop and implement efficient and compliant internal operations and prepare effectively for CMS audits with professional services and unmatched compliance tools. Contact us to learn more >>
Save the Date for the Gorman Health Group 2015 Forum. Join us April 7-9, 2015 at the Gaylord National Resort and Convention Center in National Harbor, MD. Learn more about the event >>
Application season is here: How's your network holding up?
Once again we are in the midst of application season for health plans applying to become a Medicare Advantage Health Plan, expanding their MA geographic footprint or getting into the Health Insurance Exchange space. Regardless of the scope or the specific enterprise, network adequacy and accessibility is a major cornerstone of any MA or Exchange initiative.
In addition, network adequacy and accessibility are no longer the only requirements for constructing and managing provider networks. Today's healthcare climate and market competition demands that Health Plans offer their membership provider choices which have been vetted for quality of outcomes and fiscal efficiency, ie. value based provider networks. That in turn requires health plans to find ways of evaluating their existing provider networks or newly recruited providers on the basis of past clinical and financial performance, and establish forward looking performance metrics by which to manage provider behavior and reimbursement tied to the delivery of clinical care.
Given that time is short, MA applications are due in March 2015 and Exchange networks must be in place by January 2015, many health plans are hard pressed to evaluate network adequacy, accessibility and develop appropriate reimbursement strategies on their own. That is where the Gorman Health group can help. We have a long history of helping Health Plans offer their members the best network possible. Give us a call, tell us your needs and let's work together to offer the best network product to your members.
Resources
On Friday, September 26, John Gorman, GHG's Founder and Executive Chairman together with colleague, John Nimsky, Senior Vice President of Healthcare Innovations, discussed the vehicles for achieving what could be characterized as a reengineering of the health care delivery process and its effectiveness. Join the Point today to access this webinar recording.
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.
From ACO-type incentives to bundled payments and contract capitation, to full professional and global capitation — where the potential is promising, we can help design and implement these arrangements. Find out how GHG can help >>
Save the Date for the Gorman Health Group 2015 Forum. Join us April 7-9, 2015 at the Gaylord National Resort and Convention Center in National Harbor, MD. Learn more about the event >>
The 2015 Ratings are In: Have the Stars Aligned?
The Centers for Medicare & Medicaid Services (CMS) has released the 2015 Medicare Advantage Star Ratings, and the Stars seem to be aligning with CMS' goals of the Star Ratings program. For the 40% of Medicare Advantage plans earning at least 4 Stars this year, and thus qualifying for Quality Bonus Payments, these newly-released Star Ratings illustrate the value of health plans' investments in clinical innovation and quality improvement within Medicare Advantage product offerings.
The 2015 ratings show stable or improved performance in almost 70% of the 46 Part C & D Star measures, 7 of which improved by more than one-half star from 2014 to 2015 and 13 of which earned average ratings above 4 stars in 2015. Improved health plan quality is illustrated by strong performance on preventive screening and testing measures across all domains, health plan performance measures, and measures of member complaints. During 2015, almost 60% of beneficiaries will be enrolled in one of the 158 Medicare Advantage plans which have earned at least a 4 Star Rating.
Despite these areas of strength and improvement, the Stars are not entirely aligned in the 2015 Ratings. The 2015 Ratings spotlight the ongoing challenges plans continue to face in the following areas:
- Managing chronic conditions
- Managing mental health to improve mental health outcomes
- Increasing physical activity and reducing fall risk
CMS continues to compel health plans to hardwire quality improvement and operational excellence by announcing adjustments to Star measures upon release of the ratings. With the 2015 ratings, CMS has again made Star ratings history by re-weighting the Improvement measures to 5x and announcing the following changes:
- SNP Care Management measure added with single weight
- Breast Cancer Screening and Beneficiary Access/Performance Problems measures removed from ratings and reclassified as Display Measures
- Glaucoma Testing and Call Center Foreign Language Interpreter and TTY Availability measures removed from ratings
- Adjustments made to methodology on Annual Flu Vaccine, High Risk Medication and Medication Adherence measures
With the overall national average for HOS measures below 3 stars in 2015, combined with the changes to 2016 Star measures announced in the 2015 Call Letter, the time is right to acknowledge the potential return on investment from activities aimed at improving performance across all aspects of health plan performance.
The 2015 Star Ratings continue to show opportunities for health plans to break through long-standing silos within our organizations and throughout the industry. Health plans can maximize Star Ratings by leveraging existing infrastructure, teams and processes to improve integration with providers and members. Through innovative tactical adjustments to existing processes and work streams, health plans can better integrate Part C activities with Part D activities, physical health care plans with mental health care plans, and internally-staffed work streams with delegated work streams.
Despite the approximate 85% decline in plans receiving the low performing icon (LPI), 135 plans remain on the Quality Bonus Payment bubble at 3.5 stars in 2015. Whether your plan's 2015 Star Rating is on the bubble or solidly above 4 stars, this is an excellent time to re-evaluate your 2015 strategies, work plans and tactics to best ensure that your Stars remain aligned.
Resources:
The Centers for Medicare & Medicaid Services (CMS) has been aggressively working in the background to establish the Star Ratings program for the Health Insurance Marketplaces. See what you can expect >>
Save the Date for the Gorman Health Group 2015 Forum. Join us April 7-9, 2015 at the Gaylord National Resort and Convention Center in National Harbor, MD. Learn more about the event >>