Outbound Enrollment Verification (OEV) - To call or not to call?

With the release of the 2015 Marketing Guidelines, CMS made a few key updates to the Outbound Enrollment Verification (OEV) Process. One of the most significant updates is that CMS now allows organizations to complete the OEV process via direct mail or email (if the beneficiary opted-in for email). This change actually provides significant opportunity for organizations. The way we see it, organizations will now need to choose one of two paths. The first path is to continue using outbound telephone calls to fulfill the CMS requirement. If your organization has developed and implemented an effective OEV process, by all means continue with this process. However, if you're thinking "why would we continue the current process when our OEV process has been riddled with issues of non-compliance?" Well, we agree.

If your organization has seen significant and ongoing issues with the OEV process, this is your opportunity to change that by fulfilling the requirement via another mechanism. However, if you do choose this path, it is critical that your organization develop a top notch welcome call for those new members who would have previously received the OEV call. This first touch is key in terms of identifying any possible gaps in the member's understanding of plan benefits and rules, identifying any issues of sales misconduct, as well as ensuring that your member retention program gets off on the right foot. Remember, it is always better (and less expensive) to retain a member than to obtain a member!

Please note: In CMS' memo titled "Clarification of Medicare Marketing Guidelines and Additional Agent/Broker Compensation Guidance"  that was released on August 13, 2014, CMS revises current guidance language to clarify that the OEV process applies exclusively to enrollments in which employed, captive or independent agents/brokers were involved.

Resources

On July 23, GHG leadership spoke about what provisions in the final guidelines will have the greatest impact on your organization and how plan sponsors can prepare for the upcoming changes. Download the recording >>

On September 10, join John Gorman, GHG's Founder and Executive Chairman for an exploration of why assessing your current position and developing new strategies to drive profitable market share growth is crucial for continued success. Register now >>

On September 12, join us for 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." Register today >>


Part D and Hospice Rules Mucking Up Beneficiaries' Last Days

Last week the Centers for Medicare and Medicaid Services (CMS) met with 30 hospice & healthcare organizations about suspending a new rule intended to avoid duplicate payments for hospice medications. This is a very big deal and the new rule is mucking up many beneficiaries' last days. The National Hospice and Palliative Care Organization described the meeting as "an important first step at righting the wrongs being faced by dying Medicare patients."

Previously, hospice (under Medicare Part A) paid only for the drugs that patients needed for palliation and management of the terminal illness and related conditions, and Medicare Part D covered drugs for hospice patients' unrelated conditions. Under the new rule, CMS requires a beneficiary level prior authorization process for all hospice and Part D providers to determine responsibility of drug coverage, and hospice must cover medications related only  to the hospice diagnosis.

CMS' expectations are unrealistic. Putting prior authorizations on everything adversely impacts beneficiary access to drug therapies and causes agonizing delays at the point of service. Consider this: first, it has to be determined if the drug in question is covered under Part A or D. If Part A, then you have to figure out if it's even covered under the hospice formulary and beneficiary refuses to try formulary equivalent first or drug is not reasonable or necessary  per the hospice provider if not and the beneficiary wants the drug, it will be self-pay. If it's neither Part A nor D, then the beneficiary must self-pay. If covered under Part D and the prescriber is not hospice affiliated, the sponsor has to jump through hoops, including what to do if the prescriber is unable or unwilling to coordinate with the hospice provider.Then, if the drug has prior authorization on Part D it would have to satisfy those requirements. Plans have to be able to accept and save proactive determinations from hospice. It's an administrative nightmare. For 2014 only, CMS is universally allowing Plans to treat hospice coverage determinations as exceptions. That in and of itself shows that they are not sure how best to handle this mess.

With end-stage patients (the only kind you get in hospice), it is often difficult to discern which drugs are used for symptom management and what drugs are really for chronic conditions that if in hospice should not be treated, such as diabetes or hypertension meds. The hospice industry has reported widespread confusion and disputes that have made it harder for patients to get their drugs.

Seventy senators signed onto a letter circulated by Sens. Jay Rockefeller (D-WV) and Pat Roberts (R-KS), calling for CMS to suspend the rule. "We ask that CMS immediately suspend the Guidance and begin a process to develop an alternative approach which will ensure both that the right individual or entity pays for the hospice patient's medications and that the patient get the medication that he or she requires without interruption," they write.

We agree and hope CMS goes back to the drawing board on this rule. Calm and freedom from pain should define a beneficiary's last days, not administrative hoops and preauthorizations.

 

 

Resources

If you've just submitted your HEDIS data, now is the time to analyze that data for gaps and identify interventions for your health plans, providers and members. On July 17 join John Gorman, Executive Chairman at GHG, Jane Scott , Senior Vice President of Clinical Services and Anita McCreavy, Senior Consultant, for a webinar on HEDIS reporting, the new measures and what's next. Register now >>

The rapid changes to Part D regulations make the tracking and implementation of these CMS requirements exceptionally difficult — to say nothing of actually managing to them. Contact us today to learn how we can help >>


Further Evidence That PBMs are Failing on Government Programs

At CMS' oversight and enforcement conference last week Jonathan Blanar, the agency's Deputy Director of Compliance Enforcement, presented the following slide. In this slide, you will see actions CMS has imposed against Medicare health plans in the last two years, and for what reasons. It's further evidence that pharmacy benefit managers (PBMs) are failing Medicare beneficiaries and the plans enrolling them.

 

 

PBMs have a big hand in the first category, coverage determinations, though they're not entirely culpable.  What's maddening about that tally is the fact that appeals and grievances rules in Medicare haven't changed much in the 17 years since they were first issued, and PBMs and plans are still screwing it up.  To CMS, appeals are the most important consumer protection at the point of service, so they dish those findings out regularly.

It's the second category, formulary administration, that's most disturbing.  The numbers speak for themselves.  But Blanar added this color, the most frequent findings, which included the following and are a damning indictment of PBMs as the Keystone Kops of government programs:

 

  • Unapproved quantity limits
  • Unapproved utilization management practices
  • Failure to properly administer the CMS transition policy
  • Improperly effectuating a prior authorization or exception request
  • Failure to provide a transition supply of a non-formulary medication
All these functions are WHAT PBMs DO and should be de rigueur in Medicare Part D by now. The fact that PBMs are still messing these functions up, and dragging down their plan sponsors with them, should be serious reason for concern from the compliance officer to the boardroom.

 

Resources

If you've just submitted your HEDIS data, now is the time to analyze that data for gaps and identify interventions for your health plans, providers and members. On July 17 join John Gorman, Executive Chairman at GHG, Jane Scott , Senior Vice President of Clinical Services and Anita McCreavy, Senior Consultant, for a webinar on HEDIS reporting, the new measures and what's next. Register now >>

The rapid changes to Part D regulations make the tracking and implementation of these CMS requirements exceptionally difficult — to say nothing of actually managing to them. Contact us today to learn how we can help >>


4 Points to Ponder from CMS' Oversight and Enforcement Conference

On June 26, CMS hosted their MA-PD Oversight and Enforcement conference. Not one of the topics was less relevant to the audience than another — they prepared ahead of time to present current, critical information related to their data-driven approach to oversight, best practices and common findings, preparing for an audit and enforcement actions. I was glad to see CMS invite plan sponsor staff to share their experiences. They included Todd Meek of SilverScript Insurance Company; Margaret Drakeley of Kelsey Care Advantage; Shannon Trembley of Martin's Point Health Care; Marcella Jordan of Kaiser Permanente, and Jenny O'Brien of UnitedHealthCare. Their first-hand accounts are worth your full attention.

The webinars and materials are all available to the public and I encourage you to watch them and encourage your staff to watch. Of all of the things said, the following should be enough to kick your compliance efforts into high gear:

  • Jerry Mulcahy shared that the improvement is not what CMS had hoped, and that organizations are still not testing effectively. That should warrant a hard look in the mirror to ensure your "trust but verify" methods are working. Put another set of eyes on your validation. Leverage staff with auditor experience. If the improvement is not what CMS has expected, especially after having shared their protocol and numerous best practice/common findings memos over the past few years, then consider this a red flag.
  • Statutes and regulations expect nothing but 100% timeliness. Too often we are asked for the acceptable threshold for compliance of a measure. Unless otherwise published, the expectation is 100%. Kady Flannery stressed this while explaining the 2014 method for checking CDAG and ODAG universe timeliness.
  • LCDR Lorelei Piantedosi communicated an additional best practice that didn't make the slides, and that's a 100% rejected Part D claims look-back. Seeing as how all five of the Formulary Administration common findings have been common findings published in the past, it is a wonder when an organization does not dedicate resources to this activity. (She also communicated a best practice near and dear to our hearts, but I'll leave that for another blogger.)
  • "Be transparent!" Todd Meeks says he would often times get asked about how transparent to be. Based on the fact that he shared how collaborative CMS was in aiding his organization, at times providing easier, cleaner ways to correct something, then the answer should be simple.

Think about it this way: if you draw the short straw this year for a CMS Program Audit (and I use ‘short straw' in the most lovingly way possible, CMS), then everything you add to your Self-Assessment Questionnaire should already be known by your Account Manager. We can be broken-record about this, but a Medicare Compliance Officer should know what's going on well before CMS does — it's arguably just as important to your organization that your Account Manager knows about it before Central Office.

 

Resources

From a simple gap analysis to a comprehensive, deep-diving Part C and D audit, our team can help you minimize your compliance risk and maximize your time and resources. Learn more >>

Taking the time needed to regularly assess the risk exposure of operations can be both disruptive and costly — if not impossible.  Let us augment your efforts by conducting your required annual risk assessment. Visit our website to learn more >>


PBMs are the Health Plan Industry's Achilles Heel

In this Golden Age of government programs, the health plan industry has never had more exposure to the generally poor performance of pharmacy benefit managers (PBMs).  Performance metrics in Medicare, Medicaid and ObamaCare are directly tied to PBM execution, and the recent track record of these companies means they are the Achille's Heel of insurers.

PBMs historically made most of their money on commercial insurance and have lagged on government programs, a trend exacerbated by a brain-drain of talent following a wave of PBM consolidation.  The danger has never been greater for health plans, and their choice of vendor has never been more important.

First, Medicare's Star Ratings system has several critical performance measures directly tied to PBM performance, notably those related to drug plan service, formulary administration, patient adherence to drug therapies for chronic diseases like hypertension, and readmission prevention (many hospital readmits are due to drug over/underdose post-discharge). The numbers don't lie: Medicare Part D Star ratings and formulary administration were the two leading reasons for CMS-mandated corrective action plans dropped on insurers in the last year.  Of plans scoring less than 2 Stars by performance domain, Drug Plan Customer Service came up worst in CMS's last review cycle -- followed by Member Experience with the Drug Plan, and Member Complaints, Problems Getting Care, and Improvement in the Drug Plan's Performance.  It's a dismal record and getting worse.

Then consider that the two critically-important health plan quality improvement measures -- C33 and D07 -- are now weighted 5, a first for CMS and a huge development. The concern here is that PBMs are often terrible at data management, and under these measures a plan can be reduced to 1 Star where mishandled data resulted in bias or error, or where appeals and grievances handling is in question. With that 5-weighting, this has come as a rating killer for several plans and a major vulnerability for the rest, as most don't keep good logs of non-compliance issues or audit results.

PBMs are generally good at managing the drug benefits of commercial members, but the complexity of seniors and the low-income and the previously uninsured continues to confound these companies.  Gorman Health Group ran 15 solicitations for government program PBM services for its clients in the last 12 months, and we wouldn't wrap fish in one of the responses we received. All varying degrees of suck.

In this last round of contract and service area expansions for 2015 Medicare Advantage and Part D, in our 18 years we have never seen more rejections due to PBM failings like pharmacy and home infusion network adequacy -- literally dozens this cycle, due both to PBM sloppiness and a new resolve at CMS to directly address it.

As PBMs continue to consolidate, plans need to protect themselves from weak execution by bringing renewed focus on PBM-directed Star ratings measures and most importantly, inspecting what they expect.  The delegation oversight plan for this vendor is the most important document in compliance right now.  Payers are now literally at the whim of the government programs sophistication of their PBM account manager, and that is not a comfortable place to be with literally billions of dollars and millions of seniors and the vulnerable hanging in the balance.

PBMs need to awaken to the new reality of the primacy of government programs today, and make a serious commitment to catching up.

 

Resources

If you've just submitted your HEDIS data, now is the time to analyze that data for gaps and identify interventions for your health plans, providers and members. On July 17 join John Gorman, Executive Chairman at GHG, Jane Scott , Senior Vice President of Clinical Services and Anita McCreavy, Senior Consultant, for a webinar on HEDIS reporting, the new measures and what's next. Register now >>

The rapid changes to Part D regulations make the tracking and implementation of these CMS requirements exceptionally difficult -- to say nothing of actually managing to them. Contact us today to learn how we can help >>

 


Most, if Not All, States Will Be on the Federal Exchange by 2020

Correction: June 20, 2014

An earlier version of this article misidentified the state of Washington as preparing to enter into the Federal Exchange. Though the state of Washington is having trouble with its enrollment website, Washington Health Benefit officials have clarified that Washington state has no intention of becoming part of the federal marketplace.

 

As ObamaCare launched last fall you'll recall 16 states started their own exchanges, 7 were State/Federal partnerships (effectively operated by the Federal exchange for most functions), and 27 states were supported purely by the Federal Exchange.

 

Ironically, most of these were in red states where Congressional delegations and governors and state legislatures wailed about a "Federal takeover of healthcare," and that's exactly what they got by their inaction. We knew at least 3 would have no choice but to drop out after the first year and go Federal. As preparations continue for ObamaCare's second enrollment period in October, it's now clear at least half of the state-based exchanges are going Federal in 2015.

I'll say it: I think most states, if not all, will be on the Federal exchange by the end of the decade.  The only holdouts will be states where the politics necessitate it, like Kentucky's KYNect, home of Senate Minority Leader Mitch McConnell (R-KY). KYNect has been wildly successful, signing up over 420,000 Kentuckians, many gaining health insurance for the first time in their lives, and it's giving McConnell fits in his midterm reelection bid.

The technology to run an exchange at state and Federal is duplicative, basically the same black box web-commerce architecture from over a decade ago, made wildly complex by the many state and Federal agencies involved in eligibility and enrollment. In the last several months we've seen multiple states crash and burn trying to stand it up, just as healthcare.gov did last fall.  Oregon is preparing to sue Oracle for its botched system.  Maryland's goat rodeo of an exchange launch has become a wedge issue in the governor's race. Now, Politico reports that Washington state is dealing with "back end" problems on its enrollment website, and the ObamaCare launch actually went relatively well there.

Then there's the issue of cost. The Affordable Care Act requires state-based exchanges to be self-sufficient in 2015. Those that went their own way had the buildout — or meltdown — largely paid for with Federal funds in 2011-2012. It was a vendor's Full Employment Act, with extremely mixed results. Next year's a whole different matter. State-based exchanges costs hundreds of millions of dollars annually to operate, and that won't last long in cash-strapped legislatures. The only ones left standing at the end of the decade may be Kentucky — and only as a middle finger to McConnell, as long as he may be in office — and California. Because it's California.

So for those health plans operating in states already under the Federal exchange: steady as she goes and stay current as pregame festivities begin for the second open enrollment period. If you're operating in a state doing it's own thing that's not KY or CA, you may want to consider re-speccing your systems for Federal functionality. It's only a matter of time in my opinion.

 

Resources

The launch of the Health Insurance Exchanges is the most challenging implementation in our industry's history with a patchwork of eligibility, new systems and numerous regulations. GHG can help, find out how >>


Tuesday Night's Primary Elections Were Huge. Here's What They Mean for Our Industry.

House Majority Leader, Eric Cantor (R-VA) is toast.  Trounced in his Richmond district by a nobody Tea Bagger Tuesday night. Cantor gave up his leadership position yesterday. Depending on where you sit politically, either the unthinkable or the inevitable happened.  In fact, a Majority Leader hasn't lost incumbency since the office was created in 1899.   "The defeat of the second-ranking Republican in the House by an ill-funded, little-known tea party-backed candidate ranks as the biggest congressional upset in modern memory and will immediately generate a series of political and policy-related shock waves in Washington," wrote Chris Cilizza of WaPo.

What it means for our industry is that legislatively speaking, President Obama's second term is already over.  The House will seize up like a bag of concrete in a toilet.  The most unproductive Congress in history is about to continue and worsen that record as an epic Republican leadership battle ensues.

That means Obama is left chasing his agenda through administrative action, Executive Orders, regulations and enforcement.  With brand-new and surprisingly popular HHS Secretary Sylvia Mathews Burwell on the job, expect her department to flex its muscles in ways we haven't seen, especially given the number of oversight hearings she's about to be subjected to:

  • There will be tough new rules for all government-sponsored health programs: Medicare, Medicaid and implementation of the Affordable Care Act.  The contentious new Part D rules are just the beginning.
  • There will be increasing activism in network adequacy and rate reviews of insurers in Medicare Advantage, Part D and the exchanges;
  • CMS will take a hard line on Medicare plans lagging in Star ratings and/or compliance records.  The second term of a Democratic administration is always when scores are settled; the renewed Congressional scrutiny on our favorite agency will make the paper tiger grow some claws;
  • CMS and the HHS Inspector General (IG) will finally put the pedal down on dreaded RADV audits with the promise of hundreds of millions in recoveries.
  • With wingnuts like House Oversight Chairman Darryl Issa (R-CA) salivating for domestic Benghazis, the HHS IG will likely deliver a few surprises of its own.

Every time there's a major electoral event in Washington like this, elected and appointed officials alike will usually settle back on the motherhood and apple pie of health care politics: kicking the crap out of the insurance industry and other monied interests like pharmaceutical manufacturers and PBMs.  If you're not wearing them already, it's time to pull on the kevlar boxers and the asbestos Spanx.


Lighting the Path in the Golden Age of Government-Sponsored Health Programs: Join Us for the GHG Client Forum

More than 300 guests will convene on May 1-2 at the Red Rock Casino in Las Vegas for the 2014 Gorman Health Group Forum, our annual strategic retreat for leaders in government-sponsored health programs. This year's gathering promises to be the most actionable, content-packed conference you could attend on how to succeed in this new Golden Age of government business. And when the learning and planning is done for the day, we will celebrate this unique moment in health care history as only GHG can in Vegas.  Here's what's happening this year and why you've got to join us:

  • The event features 27 content-charged sessions, including multiple presentations on Star Ratings tactics, quality improvement, risk adjustment, and compliance challenges unique to Medicare Advantage and Part D, Medicaid, and the ObamaCare exchanges
  • A keynote presentation from CMS leadership
  • An expert roster of presenters from Gorman Health Group and leading health plans in government-sponsored programs.  No fluff, no sales pitches, no history lessons -- it's all about what to do NOW
  • Approved for up to 12 continuing education credits from the Compliance Certification Board
  • The perfect off-the-strip venue to minimize distractions during the day, but close enough to the action to make plenty of bad decisions in the evenings. ;)

Based on feedback from last year's Forum, I'm speaking in three separate sessions on overall strategy and implementation planning for government programs.  If you've heard my "state of the industry" presentation before, you may think you know what to expect from me on stage.  Think again. This is my favorite gathering of the year, and I'm building three  brand-spankin' new presentations that are focused on specific steps and mileposts your organization needs to reach this year in care management innovation, risk adjustment, Star Ratings, and operational performance improvement.  In each session I'll drill down to specific steps, and we'll leave you with a self-assessment tool in our closing session to help track your progress.

Many of our clients use the Forum as an offsite retreat for their government programs executive teams, and so we offer huge group discounts to encourage it.  It's a unique opportunity for team-building and action-oriented planning and budgeting.

If government-sponsored health programs are central to your company's future, do yourself a favor and join us in Vegas. You'll come back tired, happy, and ready to win in this crazy new environment of health reform.

Don't believe me? Hear what last year's attendees thought about the event, and why they keep coming back for more.

Resources

Register today for The Annual GHG Forum held May 1-2 at the Red Rock Casino and Resort in Las Vegas. This two day event is designed to provide best practices for the decision makers of organizations serving Medicare members, Exchange beneficiaries, and the Dual eligible population.

On April 11, Bill MacBain and Jean LeMasurier will be back, and this time joined by John Gorman, Executive Chairman of GHG,  to offer insight on the Final Rate Announcement from CMS. You will walk away from this session with critical to-do items and issues to tackle in order to ensure your success in 2015 and beyond.   Register now >>

 


Innovating in 2014

CMS has developed an Innovation Center to address health care payment and service delivery models. It is a great site to find information about current Innovation Model Partners, and a place to share your ideas on how care can be delivered and paid for in ways that will lower care cost and improve quality of care. As always, the service to beneficiaries is at the heart of these initiatives, and for the program to continue, partners must be innovative.

There is also room for innovation within a Medicare health plan or Part D sponsor in terms of operations and compliance. You have heard that necessity is the mother of invention, and we often hear that departments need more money, more staff, and more technological resources in order to meet their needs.

This doesn't mean that those needs are always met. That is why it is important to be creative with the tools and resources that you have. How can you implement best practices without the budget required? Without the outline or work plan for success? Have you developed a checklist of necessary things to do, and can you accomplish those things with the staff you have? Are you and your leadership all aware of what the highest risks are to the organization, and how those risks might be affecting Star ratings?

At this year's GHG Forum, we will be addressing these types of issues facing our partners, and you will notice that we will consistently be encouraging innovation throughout the event. No problem is solved overnight — except perhaps the problem of getting a good night's sleep — that can be solved overnight! Join us and fellow attendees to gain valuable insight into what works, what doesn't, and allow necessity to spark inventive actions that you can take back to your organization. In the meantime, tell me what troubles you in your efforts to maintain an effective compliance program, or even in operational shortcomings. We are always happy to brainstorm and share ideas. You just might get a Forum discount code from me just for sharing your pain points.

 

Resources

Register today for The Annual GHG Forum held May 1-2 at the Red Rock Casino and Resort in Las Vegas. This two day event is designed to provide best practices for the decision makers of organizations serving Medicare members, Exchange beneficiaries, and the Dual eligible population.

On April 11, Bill MacBain and Jean LeMasurier will be back, and this time joined by John Gorman, Executive Chairman of GHG,  to offer insight on the Final Rate Announcement from CMS. You will walk away from this session with critical to-do items and issues to tackle in order to ensure your success in 2015 and beyond.   Register now >>


Navigators and Agents Gone Wild

Since the October 1 launch of the ObamaCare health insurance exchanges/marketplaces, there's been a growing din over the field conduct of navigators and insurance agents, in the process of enrolling eligibles on behalf of the exchanges or the health plans participating in them.  Meanwhile, the associations backing brokers are putting pressure on the Obama administration, insisting that brokers should be more involved in the enrollment process.  Add a regulatory infrastructure that is lax — at best — when it comes to training and enforcement … does anyone else have a sense of déjà vu?  It's the market conduct growing pains of the Part D inception all over again.  There is no doubt that some of the "navigators and agents gone wild" stories out there are simply anecdotal rumor mill reports coming from enterprising local reporters, or are "stings" by conservative bloggers and activists scoring cheap anti-reform points.

But it's also true that navigator and broker involvement has been controversial since the inception of ObamaCare.  You likely remember that in the early versions of the ObamaCare laws, that brokers were not even in the picture and Republicans have made great political hay so far of the navigators as the healthcare equivalent of ACORN.  Over 100 community organizations in 34 states won $64 million in Federal grants to field thousands of outreach workers to find and help enroll the uninsured, and they've been hounded mercilessly by Congressional oversight committees, local reporters and ObamaCare dead-enders.  Even the most well-intentioned brokers and navigators have had a rough go of it during these first two months.  Here's the harsh reality: Brokers face a backlog of enrollees who, for one reason or another, have not been able to submit their application.  And the current flood of beneficiaries out there stuck in the application process are overrunning the system — there isn't enough time left to process them all, ESPECIALLY when you take into account the difficulty brokers have helping consumers who are already halfway through the process before they ask for help.

To add insult to injury: Because of insufficient training, many brokers weren't prepared for how this would play out.  It wasn't until they encountered real problems, sitting next to their real clients, that the lack of training and preparation made itself painfully clear.  The deck is stacked against the broker community here, and the media spotlight will continue to get hotter.

For health plans using brokers to distribute their products in the exchanges, there is very little chance that it can or will be done effectively.  Every plan's goal is to understand and have some degree of control over how the brokers are representing the brand and the products in the field.  But the huge influx of brokers into the process, very little training beyond the bare minimum required by the feds, no guidance from CMS on broker conduct, and the enrollment portal problems --- can oversight of these agents even be on the radar?

It's all so reminiscent of the perfect storm of sales misconduct during the launch of Medicare Advantage and Part D.  In 2007 and 2008 Congress held several hearings where witnesses testified that sales agents had marketed without licenses, portrayed themselves as Medicare employees, and misled Medicare beneficiaries about plan benefits.  Some of these events were a simple matter of insufficient training or understanding of the implications of their behavior, which we are ripe to experience in the exchanges.  Others were blatant fraud. Congress's response to these incidents was the enactment of the Medicare Improvements for Patients and Providers Act of 2008 (MIPPA), which prohibited or limited certain marketing activities by sales agents and plan sponsors, required that all sales agents be trained and tested annually, and be State licensed, among other things. Plans responded by adopting leading-edge solutions like GHG's Sales Sentinel (now covering over 55,000 agents in Medicare and the exchanges) to help them onboard, manage and oversee their brokers and agents in the field.  In the exchange world, the biggest risk of all of the mayhem is a health plan's reputation -- which we've seen shattered by agent misconduct in the past. And the biggest counter balance initiative is for plans to blaze the trails when it comes to providing field agents sufficient guidance and training on conduct and repercussions, until CMS and the states catch up.

 

Resources

GHG's Sales Sentinel is the only sales oversight tool designed specifically for health care organizations operating in regulated government markets. To learn how Sales Sentinel can help your organizations agent onboarding and ongoing oversight process, visit our website >>

During the 2013 GHG Forum, Executive Chairman & Founder John Gorman, discusses how important it is to successfully train, on-board and conduct ongoing agent oversight for your Plan's success. Click here to access the recording>>

Listen as Senior Director of Product Operations at Gorman Health Group, Alex Keltner discusses GHG's Sales Sentinel, the solution to train, credential and onboard your sales force. Access the podcast here >>

Join us December 11 from 2:00 — 3:30 pm ET for a lively session with Gorman Health Group strategy and data analysis experts who will discuss actual case studies that show how plans can mine data for precious insight that can help improve performance. Register now >>