Insights | GHG Advisors

Are You Paying Twice?

Each month, health plans receive files and premium reductions for members deemed to have secondary coverage, which the Centers for Medicare & Medicaid Services (CMS) calls Medicare Secondary Payer (MSP). MSP shifts the burden from Medicare to commercial insurance companies. CMS receives information from a multitude of sources identifying beneficiaries who have other coverage appearing to be primary to Medicare. When a member is identified as MSP, CMS reduces the payment for those members to 17.3% of the full premium.

When the MSP record is valid, that premium payment is sufficient for the health plan to pay services on a secondary basis. If the MSP record is obsolete, and the plan is paying on a primary basis, the plan is paying twice: paying primary for the service and paying through reduced premiums from CMS. This can be a huge premium loss for a health plan of typically around $700 per member per month for every beneficiary incorrectly classified as MSP.

As with all things involving CMS, accuracy is critical.

Reviewing each MSP-identified individual and validating the information is the only way to ensure the member is set up correctly and the premium and claims payments are accurate. MSP validation is not a one-and-done processâ€•information can change, be inaccurate, or be out of date. Outreach validation requires diligence and persistence. Electronic Correspondence Referral System (ECRS) submissions need to be monitored for non-responses and records under development. Other coverage information and system flags need to be updated for claims reprocessing and recoveries from other insurers for claims paid as primary in error.

Do you know the status of each of your MSP members? Are you revalidating information on a regular basis? Are you sure you are not paying twice? If you aren't sure, Gorman Health Group (GHG) has delivered exceptional outcomes for our clients by recouping millions of dollars in MSP recoveries. We can help you evaluate your process and your existing MSP records to ensure you are only paying once.

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When it comes to financial reconciliation and overall membership data management, you must protect against leakage. Need help staying ahead of the reconciliation curve? GHG can work with your team to set up strong revenue reconciliation processes. Visit our website to learn more >>

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by GHG Advisors

Because They Can

The United States Senate conducted the first day of hearings Wednesday, December 9, on the high price of pharmaceuticals. The Special Committee on Aging is investigating the soaring prices of old drugs, including the overnight price hike of Turing's Daraprim from $18 to $750. Every day there is another press release about the egregious increase in pricing of a generic drug or a newly-released-to-market medication. U.S. drug prices are the highest of any in the industrialized world.

Drug prices and the strategies used to determine them are shrouded in secrecy. A recent Wall Street Journal article compared U.S. prices to Norway and several other countries. Pharma and biotech companies in the S&P 1500 average a net profit margin of 16% compared with an average of about 7% for all the other companies. Their rationale is usually they need that profit margin to support Research & Development (R&D) costs. That argument obviously doesn't apply for generic drugs. Pricing has nothing to do with recouping costsâ€”it is a decision based on market research, competitor products, and shareholder value.

What's the answer? Doctors, insurance companies, hospitals, and Pharmacy Benefit Managers (PBMs) are all struggling to figure it out. Many healthcare policy experts are advocating for Congress to pass legislation which would allow the government to negotiate pricing especially for Medicare. Since there are more pharmaceutical company lobbyists in Washington, DC, than there are members of Congress, this could be an epic struggle.

These breakthrough treatments are invaluable to patients, but the costs for the patient and insurers can be exorbitant. What programs have you put in place to help your members adhere to treatments, minimize side effects, and empower them to understand their disease, and the drugs to help treat it?

Doctors are publishing and participating in dialogues about what the true value of a cancer drug is based on effectiveness and increased patient longevity. What is the true cost of a medication? If patients actually knew, could they make informed decisions about their options?

The Turing CEO may have just opened the can of worms that Pharma did not want to ever be seen. Greed and arrogance may be the catalyst Congress needs to implement meaningful changes. One thing we all know nowâ€•pharmaceutical and biotech manufacturers charge what they doâ€¦because they can.

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Gorman Health Group can help your organization transform the delivery, payment, and care coordination efforts necessary to provide positive outcomes for your challenging patient population. If you are interested in more information, contact us here.

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by GHG Advisors

Senate passes bill repealing major provisions of Affordable Care Act

Last week, the Senate passed an Affordable Care Act (ACA) repeal bill, with a vote of 52-47. Although largely symbolic, this marks the first time the Senate has been able to pass such a bill.

The Senate voted on a bill previously passed by the House, however, because of the large number of amendments made by the Senate, the legislation now goes back to the House, where it is all but certain to pass. The White House already stated the President will veto any ACA repeal legislation, and because the Republicans do not have enough votes to override such a veto, this will be the end of the movement. Nonetheless, the Republicans will see this as a major step in their attempt to repeal the ACA, as it is the first time Congress will be able to get such a bill to the President's desk.

What's more interesting is the parts of the bill which gained some bipartisan support. For example, the "Cadillac tax" repeal amendment was overwhelmingly approved with a vote of 90-10. Although this amendment will not become law this time around, its repeal is already scheduled in talks in tax packages expected to be voted on before the end of the year. It is also unclear how the anticipated funding expected from the Cadillac tax would be replaced. It is estimated such a repeal would remove about $90 billion from the ACA over 10 years, however, the Senate's tax repeal would not go into effect until 2015.

The passage of the bill also gives a glimpse into the Republican's ACA repeal agenda should they win the White House bid next year. Some of the major provisions include:

Defunding of Planned Parenthood
Repeal of the Medicaid expansion
Elimination of reinsurance, risk corridors, and risk adjustment programs set up under ACA
Repeal of Cadillac tax
End premium subsidies for insurance purchased through the Marketplace and small business tax credits
Repeal of individual and employer mandates by lowering the penalties for non-compliance to $0
End of healthcare.gov

Despite the Republican Party's fulfillment of the promise to get an ACA repeal to the White House, conservatives have yet to offer a replacement plan. The vote on the Medicaid repeal could also create some problems for senators up for re-election in states that have expanded Medicaid, such as Pennsylvania, Illinois, and Wisconsin. At the same time, Medicaid expansion continues to gain more interest from the remaining states yet to expand. Louisiana's new governor vowed to expand Medicaid on his first day in office. Virginia Hospital and Healthcare Association recently announced their change in position to support a bed tax, which would allow the state to expand Medicaid under ACA without any additional state funding. Utah and Wyoming continue talks to come up with a plan to expand Medicaid in the next year. And although Idaho remains opposed to expanding, the legislature is discussing a plan for the state to cover basic primary care for those who do not qualify for Medicaid but earn too little for subsidies under healthcare.gov, at a cost of $32 per month.

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by GHG Advisors

CMS Clarifies Key Audit Terminology

Immediate Corrective Action Required (ICAR), Corrective Action Required (CAR), and Observation. These terms have become part of the vocabulary for Compliance specialists, auditors, analysts, managers, directors, and Compliance Officers who so often field questions from Operations. Let's consider the following scenario: Compliance has just completed an internal audit of Claims Operations and has identified findings. This leads the Ops team to ask, "Are these findings CARs or ICARs?"

Last week, the Centers for Medicare & Medicaid Services (CMS) issued a memo clarifying certain definitions which apply to their Program Audit process. This clarification was released in response to Sponsors who have provided feedback stating they feel the process for determining CARs, ICARs and Observations is not transparent, and they lack the ability to determine how audit conditions will ultimately be classified. CMS has posted clarified definitions for these terms, as well as the term Invalid Data Submission (IDS) here on their CMS Program Audit website. While I will not re-write the memo, CMS hopes these key term definitions provide the industry with the transparency it sought. In short:

ICAR: These are items CMS identifies during an audit as systemic deficiencies so severe they require immediate correction. CMS cites lack of access to medication and/or services as well as immediate threats to enrollee health and safety. ICARs count as two points in the scoring methodology.
CAR: These are items CMS identifies during an audit as systemic and requiring correction, but the correction can wait until the audit report is issued. (This does not mean wait until the audit report is issued!) CMS clarifies that CARs may affect beneficiaries but not in a way immediately impacting their health and safety, and count as one point in the scoring.
Observation: These are non-systemic, typically one-off issues of non-compliance identified during the audit. No points are assigned in the scoring methodology for Observations.
IDS: This is cited when a Sponsor fails to produce an accurate universe within three attempts. This will be cited in 2016 for each element which cannot be tested, and counts as one point in the scoring.

CMS directs plans to send any questions to their mailbox at part_c_part_d_audit@cms.hhs.gov. Take it from me, the CMS team is responsive to posed questions. An informed and more prepared industry will hopefully make for a smooth 2016 audit season for CMS and for Sponsors.

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In addition to monitoring your operations and auditing the organization's performance, CMS also audits the compliance function. In recent years many CMS sanctions have been issued as the result of a Compliance Program that was determined to be ineffective. Let us help you create a culture of compliance. Contact us today to get started >>

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by GHG Advisors

Government Shutdown Deadline Nears

Less than a week remains for Congress to agree on a $1.1 trillion funding bill in order to avert the threat of yet another government shutdown. The deadline to pass this bill is December 11, 2015, although Congress could technically use a stopgap measure to buy an extra week, pushing the deadline to December 18. As previously reported, a shutdown would have significant consequences for all government agencies, including the Department of Health & Human Services (HHS). Although most Medicare and Medicaid services are considered necessary to the public welfare and would thus escape much of the repercussions of a shutdown, operations at the Centers for Medicare & Medicaid Services (CMS) would nonetheless be affected.

So what is the likelihood of a shutdown occurring?

The House Democrats rejected the Republican's offered funding bill on Monday and are planning an alternative package in response. The Democrats cite more than 30 policy riders making the package unacceptable to their side. The aggressive response from the left wing suggests they won't easily back down this go-round, however, the possibility of a shutdown is less likely than estimated during the stand-off a few months ago.

For one, unlike a few months ago, Planned Parenthood funding has not been as much of a battle this month. This time, the Syrian refugee crisis, terrorist attacks, and immigration policies bear the brunt of the debate. Congressman McCarthy also hinted on Monday he did not predict the Planned Parenthood tension to hinder the passage of a funding bill this year. The new Speaker, Paul Ryan, also has a lot riding on averting a government shutdown, as such an event six weeks into the job would be disconcerting to the party. And, unlike earlier in the year, with key members of both parties unwilling to use the threat of a shutdown to further their agendas, the likelihood a funding bill will pass is very good.

Resources

Registration for the GHG 2016 Forum is now open! This year we are offering a tiered pricing schedule. Register between now and February 14 to receive the $1095 price. Come February 15, the price increases to $1,295.Register today >>

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by GHG Advisors

AEP Is Winding Down, But Your Work Is Not Over!

As the Annual Election Period (AEP) begins to wind down, you have a pretty good idea of where you will end up this AEP. Whether you knocked the socks off your competition or missed your goals, now is the best time to assess your marketing and sales strategies in preparation for 2017!

Typically, we all have to perform an analysis for senior management showing where the leads and sales came from and what the costs per lead and sale were. Based on that information, we want to understand what changes need to be made or tested for next AEP to increase lead generation and decrease the cost per lead or sale.

But that shouldn't be the end of the analysis — now is the time to do the following:

Conduct an AEP Process Analysis — From an operational perspective, what went right and what didn't go as well as expected? Were there reprints? What were the call center stats — were they better or worse than last year? From an operational perspective, what would we like to change from this year to the next? What do we have to do internally/externally to accomplish that?
Vendor Assessment — What vendors over-performed or performed as expected? Do vendors need to be replaced? If so, the Request for Proposal (RFP) process should probably be completed by the end of the first quarter.
Review Competitive Creative — There is nothing wrong with understanding what competitors are doing and seeing where you might need to strengthen your own creative in the next year.
Review the sales distribution strategy to understand where the sales opportunities may have been missed and where they were most successful.
Deep-dive Evaluation of Lead Generation to Member Onboarding — Since now is the time when we really remember all of the pain points and accomplishments, we want to document them to ensure we make changes where needed and expand the successes.
Look back at the work plan/tactical execution plan to understand where more time is needed next year for a better execution come AEP.

Based on our experience, now is the time to conduct the assessment — before everyone has forgotten what needs to change and before the frustration of a missed date or opportunity becomes a distant memory. Gorman Health Group (GHG) has helped several organizations with this type of assessment — to provide that outside-in perspective which is honest and non-partisan.

Have questions? Contact GHG at ghg@ghgadvisors.com.

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Gorman Health Group's marketing experts have developed strategic plans for hundreds of Medicare Advantage Plans. We will position you for the challenges â€” and opportunities â€” posed by health reform, designing a strategy that takes into account your service area, market environment, core competencies, and vision of the future. Visit our website to learn more >>

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by GHG Advisors

Miss Our Star Ratings Webinar? Here Are the Top 5 Takeaways

With just a few more weeks remaining before the 2018 Star Ratings cycle begins, we are on the cusp of yet another exciting iteration of program changes and updates within the Star Ratings program. In case you missed our Star Ratings webinar, here are our top five takeaways from the session:

Silo-busting will be more important than ever to earning a 4 Star Rating.

Despite the absence of any new Star Ratings measures in 2017, the areas to be measured by the new 2018 Star Ratings measures proposed by the Centers for Medicare & Medicaid Services (CMS) cut right to the heart of some silos still remaining within health plans. For example, many, if not all, health plans have developed their Medication Therapy Management (MTM) programs within their pharmacy department, and many MTM programs are outsourced entirely through the Pharmacy Benefit Manager (PBM). However, CMS is proposing addition of the Medication Reconciliation Post Discharge measure as a Part C Healthcare Effectiveness Data and Information Set (HEDIS®) measure. Simultaneous success on this new HEDIS® measure and Consumer Assessment of Healthcare Providers and Systems (CAHPS®) measures will require a well-coordinated, cross-functional evolution of medication reconciliation workflows into time-sensitive, clinically-appropriate patient engagement workstreams. CMS' proposal to introduce the new statin therapy measures without classifying both as either Part C measures or as Part D measures will be a true test of internal silo-busting within health plans. From provider reporting and outreach to member engagement and outreach, simultaneous success on these measures and CAHPS® measures will require strategic, innovative use of data and analytics to drive a seamless experience for all. CMS' proposal to introduce the new asthma-related medication measures (which contain significant adherence components) as HEDIS® measures will reinforce this need.

Star Ratings must be approached strategically and managed as a program.

Approximately 35% of the 2016 Star Rating is driven by patient experience, complaints, and measures capturing access. An additional 11% is driven from the remaining CAHPS® survey measures and the Health Outcomes Survey (HOS) measures, and yet another 12% is based on the contract's overall improvement or decline from one year to the next. Mathematically, that means less than 50% of the Star Rating is now driven by traditional measures of clinical quality. This, combined with the breadth, depth, and scope of the individual measures which comprise each of these categories and the expertise necessary to improve performance on individual measures, necessitates use of a highly-strategic approach to designing a Star Ratings program in order to ensure time and resources are invested where most needed in a way that is seamless and well-coordinated to members and providers.

Your members' perceptions matter. A lot.

The combination of patient experience and complaints, measures capturing access, and the other survey measures comprise 46% of the Star Rating. This, combined with the fact the range between a 2 Star Rating and a 5 Star Rating was less than 10% for 8 of the 1.5-weighted CAHPS® measures in the 2016 ratings, requires us to be strategic and purposeful in all of our operational decision-making. Every program, phone script, and member mailer should be evaluated from the member's perspective. It is no longer enough for us to do the right thing — now we have to both do the right thing and manage the member's perception of what we are doing. With this in mind, it's important for us to ask:

Will the member understand why we're calling/mailing?
Will our request resonate with the member's current health status?
Will the member perceive our outreach to be well coordinated?
Will our outreach align with his/her doctor's recommendations?

Each of these questions is important to consider as part of every decision made by every team in the new era of Star Ratings.

Change is the only constant in Star Ratings.

From the changes introduced in the 2016 Star Ratings program to the future changes proposed in CMS' recent Request for Comments on potential future changes to the Star Ratings program, it is clear change will continue to abound within Star Ratings. We must prepare for growth in the number of Star-rated Medicare Advantage plans, an interim and permanent solution to address the impact of socio-economic and disability status on Star Ratings, and the new measures proposed by CMS as potential 2018 Star Ratings. Educating providers, staff, and the executive team, adjusting reports and analytics, and enhancing strategies and tactics to account for these changes will require increased investment of resources and expertise during the coming months.

Measure, manage, then act.

Success will depend on purposeful activity during the coming months. With the extent of changes on the horizon, it will be important to stay focused on identifying the actions needed for success and executing such tactics swiftly. We can enhance the member's experience (and our Star Ratings) by conducting the right action, at the right time, using the right channel.

The first quarter is a great time for strategic planning and reflection. Not only is there still opportunity to influence your 2017 Star Ratings, but there is also time to refine and enhance your 2016 tactical roadmap to help you earn â‰¥4 Stars next year.

by GHG Advisors

Evolution of Validation: Selecting an Independent Auditor

The Centers for Medicare & Medicaid Services (CMS) audit validation process has evolved over the past few years. Here is what you should know about the changes and how to best prepare to contract with an Independent Auditor, or IA.

Let's go back to 2012. CMS was conducting the validation of audited Sponsors' corrective action plans (CAPs) by retesting areas found to be problematic. While the terminology has changed, the charge was led at that time by the Regional Office. In 2013, validation became an activity conducted by the Medicare Parts C & D Oversight and Enforcement Group (MOEG) at Central Office and Regional Office staff. Any items that resulted in a Corrective Action Required (CAR) or an Immediate Corrective Action Required (ICAR) were subject to validation.

As part of the 2013 validation timeline, the Sponsor had seven days from the issuance of the final audit report to submit a CAP for each condition. If we reference the 2014 Part C and Part D Program Audit and Enforcement Report, CMS outlined the average number of days which elapsed after an audit notice was issued.

If we take a look at the average days elapsed from the Exit Conference to the Final Report Issued date, the number of days elapsed has decreased, from 241 days in 2011 to 99 days in 2014. Based on the last year of reported data, plans still had a healthy three months from the verbal acknowledgement of CARs and ICARs (that is, the Exit Conference) to the issuance of the final report in order to implement corrections. In theory, by the time the final report was issued, some issues could have been corrected and, therefore, could have been ready for validation. However, time had to elapse for CMS to approve the CAPs, and after that point, CMS allowed Sponsors another 90 calendar days from that approval to implement and test the results of those CAPs. That's a lot of time when you look at it from the beneficiary perspective.

Fast forward to today — CMS is exercising their authority to require a Sponsor to hire an IA in order to validate if deficiencies found during a CMS program audit have been corrected. In a memo released on November 12, 2015, CMS confirms they will not provide recommendations on IA firms. Instead, they require the Sponsor to attest to both the independence of the IA as well as an absence of conflicts of interest. They point to the 2010 guidance for the selection of a Data Validation auditor for examples of relationships not meeting the standard for organization independence.

We are united with CMS' recommendation that Sponsors solicit proposals to select an IA early in the post-audit phase. Speaking from the auditor standpoint, it is much better for all parties involved to plan early, so exceed CMS' expectations and seek proposals as soon as possible. It's better to have that agreement in place ahead of time, rather than waiting until CMS sends you their instruction to hire an IA. This will give you the time to evaluate your options, so you can best determine their experience and subject matter expertise. When you are accountable to CMS to validate corrections, it is particularly important to partner with someone you can trust to apply a skilled eye to the validation activities. Otherwise, you may be subject to further scrutiny by CMS, which is the last thing any Sponsor needs when coming to the close of their audit process.

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Determining conflict of interest is the responsibility of the Plan Sponsor and can be subject to interpretation. Not every auditor that a Plan Sponsor has used in the past is necessarily a conflict of interest. Contact us for further questions >>

Registration for the GHG 2016 Forum is now open! This year we are offering a tiered pricing schedule. Register between now and February 14 and pay $1,095, the price increases to $1,295.Register today >>

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by GHG Advisors

Update on CMS Spotlight on Provider Directories and Network Adequacy

As we learned from the 2016 Call Letter, the Centers for Medicare & Medicaid Services (CMS) is placing a renewed focus on Medicare Advantage plans' provider network with emphasis on both online provider directories and network adequacy. CMS plans to monitor compliance of plans' adherence through direct monitoring with additional contract funds and through the development of a new network adequacy audit protocol to be tested in 2016 which will determine whether the provider network meets published CMS adequacy standards. The compliance and enforcement of the new protocols will include civil money penalties and enrollment closures.

Recent beneficiary complaints have brought into focus the accuracy, or lack thereof, with Medicare Advantage Organizations' online provider directories. Beneficiaries, and sometimes-referring providers, have shown frustration in attempting to make an appointment only to find the provider is no longer accepting new patients, has moved, or is no longer participating with the plan. CMS has supplemented their current guidance on provider directories with additional updates on August 13 and November 13, 2015, and expects plans to:

Establish and maintain a proactive and structured process in which to verify the availability of its contracted providers.

In their August 13, 2015, update, CMS clarified the requirement does not apply to entities such as hospitals, and plans should use a method likely to achieve the highest response rate. This process was further updated on November 13, 2015, and effective immediately will now include outreach on a quarterly basis to verify:

There has been no change in a provider's address or phone number and determine if the provider's panel is open or closed to new patients. CMS provided additional guidance that plans should include a notation in the online directory identifying providers who are accepting new patients or a notation identifying providers who are not accepting new patients;
Establish a policy to review and address beneficiary complaints when they are denied access to a provider(s); and
Include a provision for real-time updates to the online directory. In a memo released on November 13, 2015, CMS further defined "real-time" to mean within 30 days to be consistent with other Marketplace regulations.

It is important to note CMS' core focus remains ensuring provider directories are accurate for Medicare beneficiaries and their caregivers who rely on them to make informed decisions regarding their healthcare choices.

As you prepare to meet the new challenges for maintaining an up-to-date provider directory, changes to network submissions for service area expansions, or preparations in anticipation of the network adequacy (pilot) audit, please feel free to reach out and let us know how Gorman Health Group can assist you!

Contact me directly at emartin@ghgadvisors.com to learn more.

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At Gorman Health Group, we can help you decide what payment models are appropriate to your unique circumstance and support your implementation efforts. Learn more >>

Registration for the GHG 2016 Forum is now open! This year we are offering a tiered pricing schedule. Register between now and November 30 to receive the biggest savings at $795. Come December 1, the price increases to $1,095.Register today >>

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by GHG Advisors

Star Ratings: Preparing for 2016

With the Centers for Medicare & Medicaid Services (CMS) release last week of its annual Request for Comments on Enhancements to the Star Ratings program, we now have our first official glimpse into the potential changes which could be introduced in the 2018 Star Ratings.

Consistent with CMS' recent about-face on the impact of socio-economic characteristics on a plan's Star Ratings, CMS laid out two potential interim analytical methodologies which may be used to help account for the Star Ratings differences of low income subsidy (LIS)/dual eligible (DE)/disabled members. CMS indicated these interim analytical adjustments will be interim solutions only and could be used while CMS completes its broader work on a more effective quality structure and payment model which more effectively supports the unique needs of LIS/DE/disabled members. CMS has requested health plan feedback regarding both potential options as well as recommendations for any additional permutations and/or hybrid approaches based on the two options presented.

CMS is not planning to add any new 2017 measures, which is welcome news to health plans, to be certain. However, CMS announced a number of potential new 2018 measures, some of which will bring transparency to clinical areas new to the Medicare Advantage Star Ratings program. Some of the new areas which could be Star rated include asthma medication management (including dispensation of, and adherence to, asthma medications), statin therapy prescribing patterns, and hospitalizations for preventable conditions (which will assess the quality and coordination of ambulatory care). In sharp contrast to recent history, in which we have seen very few new clinical measures added as Star Ratings, the nature and scope of these new measures will put plans squarely back in the driver's seat to initiate new types of clinical quality improvement work with their providers.

The proposed retirement of the High Risk Medication (HRM) measure (which had an average national 2016 rating of 4.1) to the Display page and the continued retention of the Improving Bladder Control measure on the Display page should be considered temporary by plans. These measures continue to receive attention from CMS and measure developers and could easily be returned as Star Ratings Measures in the future — the Improving Bladder Control measure potentially as early as the 2018 Star Ratings and the HRM measure potentially as early as the 2020 Star Ratings.

As is always the case with CMS' announcements regarding potential changes to the Star Ratings program, we know final decisions will not be made until after the measurement periods are complete. To successfully cope with this reality, health plans must continue monitoring CMS' updates and announcements in the upcoming Advance Notice and Final Call Letters while simultaneously enhancing current workflows to incorporate strategic elements of the proposed changes. As we learned last spring, CMS gives strong consideration to health plan feedback regarding any proposed changes to the Star Ratings program.

With the potential Star Ratings changes on the horizon, this is a great opportunity to revisit your 2016 Star Ratings work plan to ensure you are ready for success. It's a great time to evaluate reports, analytics, member/provider workflows and targeting, and budgets to make sure you're prepared to earn your 4-Star Rating next year.

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Gorman Health Group's team of experts can help your organization adapt to the new clinical areas emphasized in the Request for Comments, develop or enhance care coordination within your programs, or evaluate the effectiveness of your current Star Ratings program. We can also help you educate your staff and providers on the nuances and clinical implications of these new measures. Visit our website to learn more >>

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by GHG Advisors