Why Is Conducting a Part D Operational Assessment so Important?
Medicare Part D is a complex program that is continually in motion. The Centers for Medicare & Medicaid Services (CMS), in an attempt to provide clarity to stakeholders, actively publishes updated guidance to sponsors to assist in process improvement and encourage optimal beneficiary outcomes and experience. Keeping up with Health Plan Management System (HPMS) memos, best practices, yearly call letters, and webinar information is challenging. Dynamic and ever-changing guidelines inevitably bring uncertainty and risk. Understanding these guidelines and operationalizing a compliant program is key to a successful program and financial sustainability.
For an organization to succeed in this fluid environment, it must achieve higher quality and Star Ratings, improve beneficiary satisfaction and retention, while staying on top of compliance and operational efficiency. CMS expects all plan sponsors to carefully and regularly evaluate risks to their organization. Emphasis is placed on compliance, identification and prevention of fraud, waste, and abuse (FWA), and oversight of first-tier, downstream, and related (FDR) entities. Additionally, in recent years, there has been increased focus on coverage determinations, appeals, and grievances. All of these areas can have an impact on a plan's Star Ratings and financial outlook.
Conducting a comprehensive operational assessment is an excellent strategy to identify a plan's strengths and weaknesses and evaluate the adequacy and reliability of operations. Information is gathered and evaluated from multiple sources such as current policies and procedures, oversight activities, reports, and operational processes. Comprehensive evaluation of this information will proactively identify areas of risk, allowing plans to strategically adapt to the changing environment to reduce identified risks. Gorman Health Group, with our team of industry experts, can provide an assessment of areas of greatest risk exposure along with solutions based on best practices, ensuring the organization is well positioned for future success.
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Our broad array of services can assist you in post-audit remediation, implementation of best practices, PBM contracting and implementation, interim staffing, clinical process re-engineering, Star Ratings improvement, and claims and PDE assessment and adjustments. Visit our website to learn more about our Part D services >>
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Health Plans Need to Start Talking About Disparities in Care
On the heels of a recent groundbreaking RAND report on racial disparities in Medicare Advantage (MA), the US Department of Health & Human Services' Office of Civil Rights (OCR) issued a regulation that requires serious attention in health plans participating in MA, Part D, Medicaid, and ObamaCare. It's a game-changer in advancing health equity and reducing disparities.
The new regs, implementing Section 1557 (the nondiscrimination provision) of the Affordable Care Act, prohibit discrimination, marketing practices, or benefit designs that discriminate on the basis of race, color, national origin, sex, age, or disability. This will escalate disparities from simply being a "quality improvement need" to being a huge compliance issue. It goes without saying that an investigation of your plan by the civil rights cops splashed across local news would be devastating. As the Centers for Medicare & Medicaid Services (CMS) has begun more aggressively using their data to identify these disparities, health plans certainly should begin doing the same.
The final rule prohibits sex discrimination in healthcare, including by:
- Individuals cannot be denied healthcare or health coverage based on their sex, including their gender identity and sex stereotyping. These last two items are of particular importance given transgender policy enforcement is relatively new. OCR has prosecuted cases recently where transgender patients were discriminated against in hospital admissions and room assignments, denying mammograms to transgender females, denial of gender reassignment surgery as "cosmetic," and harassment by medical transport drivers.
- Women must be treated equally with men in the healthcare they receive and the insurance they obtain. OCR has prosecuted several cases recently where hospitals assigned male guarantors when a wife obtained services but not the other way around.
- Categorical coverage exclusions or limitations for all healthcare services related to gender transition are discriminatory.
- Individuals must be treated consistent with their gender identity, including in access to facilities.
- Sex-specific health programs or activities are permissible only if the entity can demonstrate an exceedingly persuasive justification.
The regs also include important protections for individuals with disabilities and those with limited English proficiency by:
- Requiring covered entities to take appropriate steps to ensure communications with individuals with disabilities are as effective as communication with others.
- Covered entities must post a notice of individuals' rights, providing information about communication assistance, among other information.
- Covered entities are required to make all programs and activities provided through electronic and information technology accessible to individuals with disabilities, unless doing so would impose undue financial or administrative burdens.
- Covered entities cannot use marketing practices or benefit designs that discriminate on the basis of disability.
- Covered entities must make reasonable changes to policies, practices, and procedures, where necessary, to provide equal access for individuals with disabilities.
- Requiring covered entities to make electronic information and newly constructed or altered facilities accessible to individuals with disabilities and to provide appropriate auxiliary aids and services for individuals with disabilities.
- Requiring covered entities to take reasonable steps to provide meaningful access to individuals with limited English proficiency. Covered entities are also encouraged to develop language access plans.
Resources
CMS recently announced the release of the 2017 Medicare Marketing Guidelines for Medicare Advantage Organizations and Part D Sponsors, which include added language, clarifications, and new requirements. Join Regan Pennypacker, GHG's Senior Vice President of Compliance Solutions, and Carrie Barker-Settles, Director of Sales and Marketing Services, on Tuesday, June 28, from 1-2 pm ET, to discuss what provisions in the final guidelines will have the greatest impact on your organization and how plan sponsors can prepare for the upcoming changes. Register now >>
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Medicare Marketing Guidelines Summary of Changes — Have They Left You Scratching Your Head?
On June 10, 2016, the Centers for Medicare & Medicaid Services (CMS) announced the release of the 2017 Medicare Marketing Guidelines (MMG) for Medicare Advantage Organizations (MAOs) and Part D Sponsors.
Added language, clarification, and new requirements seem to be the theme with the recent updates. So how do these changes affect business as we prepare for the 2017 Annual Election Period (AEP)?
At Gorman Health Group (GHG), our team of subject matter experts comes together to provide you with clarification around a few key changes from the final MMG Summary of Changes and recommendations for your organization.
Marketing — Diane Hollie, Senior Director of Sales & Marketing Services, says, "Although CMS has stipulated provider and pharmacy directories are considered non-marketing material, it doesn't mean the provider directories don't get submitted to CMS. In fact, all plans must submit their hard copy provider directories to CMS on an annual basis."
CMS is now referring Sponsors to the Medicare Managed Care Manual, Chapter 4, for provider directory guidance and the Prescription Drug Benefit Manual, Chapter 5, for pharmacy directory guidance — making it a more complicated process. The following are just a couple of provider directory rules found in Chapter 4, which were announced earlier this year in a 4/28/16 Health Plan Management System (HPMS) memo.
- All hard copy directories must be uploaded into HPMS as a non-marketing material under the XXX submission code.
- All hard copy directories must be uploaded prior to making the directory available by September 30.
- Because provider directories are considered non-marketing, MAOs should not include a status after the material ID.
- To distinguish the provider directories as non-marketing, the following material ID should be used: plan's contract number, followed by an underscore, followed by a series of alpha numeric characters chosen at the discretion of the plan, followed by an underscore, followed by the letters "NM." Example: HXXXX_ABC124_NM
While it is noted the MMG has referred readers to the PDBM, Chapter 5, for pharmacy directory guidance, there is no cross-referenced information. This could be an indicator a revised Part D Chapter 5 will soon be released. Without it, Sponsors will be left scratching their heads.
Sales — Carrie Barker-Settles, Director of Sales and Marketing Services, understands the importance of agent/broker oversight and Sponsor sales activities. "Helping plans/Part D Sponsors and agent distribution channels navigate the dos and don'ts of the rules and regulations can be very overwhelming, but at GHG, we can make that challenging task less daunting for both."
Below are just some of the changes relating to sales oversight:
- Telephonic Contact — Plans/Part D Sponsors may call their current MA and non-MA enrollees or use third parties to contact their current MA and non-MA enrollees about MA/Part D plans. Examples of allowed contacts include calls to enrollees aging into Medicare from commercial products offered by the same organization and calls to an organization's existing Medicaid/Medicare-Medicaid Plan (MMP) enrollees to talk about Medicare products. The updated guidance clarifies, when discussing Medicaid products, Sponsors must follow all applicable Medicaid marketing rules. Plans/Part D Sponsors, sellers, and telemarketers may conduct these telephonic activities, but we recommend you fully understand all the regulations for both unsolicited and solicited contact before reaching out to Medicare beneficiaries.
- Compensation Payment Requirements — Whether you use employed, captive, and/or independent agents, you must inform CMS yearly by the end of July which channels you will be using as well as the compensation payment rates or ranges. The compensation structure must include:
- How the Plan/Part D Sponsor intends to disseminate compensation, specifying payment amounts for initial and renewal compensation.
- CMS has clarified in the revised guidance the compensation structure must stay the same for the compensation year that was put in place by October 1.
- How the Plan/Part D Sponsor intends to disseminate compensation, specifying payment amounts for initial and renewal compensation.
Some Plan Sponsors may have already been following this process, but if not, yearly requirements outlined in the MMG suggests all Plan Sponsors check policies and procedures to ensure they adhere to their clarification.
"I come from a trust but verify world," says Regan Pennypacker, Senior Vice President of Compliance Solutions," and when the updated MMG is released, it's important Compliance teams disseminate the document to ensure affected business units can determine impact." "It's also important," she states, "to reconcile and ensure supplemental memos and clarification emails sent between revisions have also been rolled into the new guidance." For example, the Part C aspects of the August 13, 2015, "Clarification of CY2016 Medicare Marketing Guidelines" has indeed been rolled into the MMCM, Chapter 4, but as noted above, the Part D aspects pertaining to pharmacy directories has not. "This means plans will need to continue to reference that memo to ensure they are following the guidance as it pertains to pharmacy directories."
"Overall," states Regan, "it will be important for Compliance to partner with Sales and Marketing staff to ensure adherence to all changes and clarifications."
We have highlighted just a few of the key changes, but to learn more, register to join our upcoming webinar on June 28, 2016, from 1 - 2 pm ET.
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Once you have your PBPs in place (we can help with that, too), our teams can develop or review your sales collateral and creative by product type to help ensure your high-impact messaging is both targeted and compliant. Visit our website to learn more >>
Gorman Health Group's Sales Sentinel™ is a flexible, module-based software solution with the ability to onboard agents, provide training, manage ongoing oversight activities and pay commissions. Created by GHG, Sales Sentinel™ was designed to address the specific needs of government managed care organizations. Request a demo today >>
The Formulary Season
It's the formulary season, and you should be in the home stretch for your Health Plan Management System (HPMS) submission. What's on the formulary and what changes were made to the formulary are among the top reasons why members either enroll in or disenroll from a health plan. Manufacturer price increases over the past two years and the number of high-cost specialty drugs released to market make formulary decisions and utilization increasingly difficult and significant to the health plan's bottom line. With an average generic medication utilization rate of 80-85%, there is limited movement to improve. Some thoughts to consider:
Custom vs. Template
Offering a custom formulary targeted to treat a subset of enrollees with a chronic condition seems to be the wave of the future through value-based insurance design. Counterarguments center around a probable increased cost for the Pharmacy Benefit Manager (PBM) administering a custom formulary as well as increased compliance risks for the maintenance and updating of a custom formulary.
Cost-Sharing
Monthly member out-of-pocket cost-sharing for commonly used formulary brand and generic drugs varies widely across Part D plans; for five of the ten top brands, monthly costs can vary as much as $100. Medications (including the specialty tier) with the highest cost share are generally non-formulary brand medications. Non-formulary specialty medications are sometimes ten times higher if they are non-formulary.
Utilization Management
The number of prior authorization (PA) edits approved through the coverage determination request process should be assessed by the plan. If over 90% of the requests are approved, is it really cost effective for the plan (especially if coverage determinations are delegated to the PBM) to continue to utilize the edit? That expense may be better utilized in performing retrospective reviews to ensure medications are being used for approved indications.
Coverage Gap
For 2017, members are responsible for 40% of the cost of brand name drugs and 51% of the cost of generic drugs in the coverage gap. Plans should determine the potential medical costs (emergency room, physician visits, hospitalizations) of members not taking their chronic medications or only taking a subset that they can afford in this coverage gap period. Providing additional gap coverage for medications makes sense in some benefit/risk scenarios.
Resources
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. Gorman Health Group's broad array of services can assist you in post-audit remediation, implementation of best practices, PBM contracting and implementation, interim staffing, clinical process re-engineering, Star Ratings improvement, and claims and PDE assessment and adjustments. Visit our website to learn more >>
Stay connected to industry news and gain perspective on how to navigate the latest issues through GHG's weekly newsletter. Subscribe >>
Why are the Dual Eligible Demos Such a Hot Mess?
There's no avoiding the steady stream of bad news facing the Centers for Medicare & Medicaid Services (CMS) financial alignment demonstrations for dually eligible beneficiaries. Enrollment is declining, beneficiaries are opting out at epic rates, and leading states like California are slowing their efforts despite crushing budget realities. Dozens of health plans have invested millions to participate in what's become a hot mess. Where do we go from here?
An early priority of the Affordable Care Act was to give states great flexibility in transitioning dual eligibles into health plans. Back in October 2013, over 60 participating health plans began enrolling dual eligibles through three-way capitated contracts with 13 states (VA, MA, IL, OH, CA, TX, SC, MI, NY, MN, CO, WA, RI) and CMS, representing a $40 billion annual revenue opportunity. After a strong start through the first half of 2015, the pilot programs for the most vulnerable patients in the U.S. health system started hemorrhaging. Net enrollment has declined for the last 4 months. Overall, only 30% of eligible beneficiaries are enrolled — way below expectations. The demos have been plagued by beneficiary opt-outs over 70% in some states, scared off by anti-managed care providers and advocacy groups. In some states, over one-third of eligibles "simply can't be found."
Some of these issues, like difficulty in locating dual eligibles given their widespread transiency, come with the territory and call for a much more aggressive community-based outreach and education campaign by state officials prior to the launch of these demonstrations. High rates of opt-outs show that outreach also must include providers and advocacy groups, especially those for the disabled, who "defined the terms of the debate" with beneficiaries and talked them out of participating before launch. One advocate noted, "Seniors have many doctors because they have multiple chronic conditions. Even the thought of losing a physician … is enough not to sign up."
Last year, CMS conducted an independent analysis of the state demos, which found that states didn't realize how much it would cost to implement, especially in IT infrastructure. They found huge issues with enrollment, despite a phased approach, and found health plans had a hard time keeping up with basic reconciliation, coverage and payment transactions. With this came the issue of trying to find beneficiaries to complete their initial health assessments and to educate them on the benefits of the demo in the first 90 days of enrollment. Large-scale demos, such as in Los Angeles County, were plagued with problems, whereas less ambitious launches went more smoothly. This argues for more 1915(c) home and community-based services waivers on a smaller scale and less monster 1115 waiver projects.
But the fundamental issue remains — the enrollment process —and here is where policy must change. Focus groups show that more than 40% of opt-outs were unaware they had done so — this in a state where 89% of enrollees are satisfied with the program once they are in it. This argues that voluntary enrollment is counterproductive to the goal of enrolling dual eligibles in coordinated care. Massive community-level outreach to beneficiaries, advocates, and providers must be required and paid for, followed by passive and/or facilitated enrollment processes that automatically enroll beneficiaries into plans unless they affirmatively choose otherwise. Anything less only results in pilot projects that fail to thrive.
Resources:
Join us on Thursday, May 26, from 1-2 pm ET, for an in-depth webinar analysis of the key changes finalized in the new Medicaid regulation, how these changes will affect states and managed care plans, as well as how to adapt. Register now >>
More than 200 health plan clients and an additional broad range of other industry participants each year trust Gorman Health Group's team of professionals to deliver expert counsel and tools to help them meet their goals. We pride ourselves on having both day-to-day alignment with the latest CMS guidance and the long-term strategic vision to keep it all in perspective. Contact us today >>
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The Effect of the New Part B Drug Payment Proposal on Medicare Advantage and Part D
It's no secret drug costs have skyrocketed in the past decade, and drug payment policymakers face an uphill battle in figuring out how to curb this exponential growth. The Centers for Medicare & Medicaid Services (CMS) has already taken a beating on its proposal to test a new alternative payment design to pay for drugs covered under Medicare Part B, calling into question whether this new methodology will go through looking anything like originally proposed. Part B spending is just a fraction of drug spending in Medicare, covering the drugs administered by a physician or hospital outpatient department. A major question for our industry is what effect this new proposal will have on Medicare Advantage (MA) and Part D plans if implemented.
Part B spending on drugs has increased annually by 7.7% since 2005. Currently, most Medicare Part B drugs are paid using the Average Sales Price (ASP) plus a statutorily mandated 6% add-on. This creates an incentive to prescribe more expensive drugs due to the higher payment amount. Under the new model, Medicare Part B would pay the ASP plus an add-on of 2.5% and a flat fee of $16 per drug per day. The lower add-on and inclusion of the flat fee would decrease the incentive to provide more expensive drugs as the revenue for the drugs would be more evenly distributed. CMS will then roll out the second part of the experiment in which they will test several other pricing methodologies currently utilized by commercial health plans and pharmacy benefit managers, such as discounting or eliminating cost-sharing, providing feedback on prescribing patterns and decision support tools, basing pricing on a drug's clinical effectiveness, and setting benchmarks for a group of therapeutically similar drug products.
The industry was quick to respond, arguing the proposal will lower incentives to give beneficiaries access to vital drugs due to the cost, leading to a reduction in patient outcome as well as patient satisfaction. Some physician groups threatened, if this new payment methodology doesn't adequately cover the cost of the drug, a physician would opt not to prescribe the more expensive, even if more appropriate, medication. The proposal is also facing much scrutiny from both sides of the aisle in Congress, although some Democrats did offer their support. The House and Energy Committee will hold a hearing on the demo on May 17, 2016, along with a bill aiming to quash the demo entirely.
We probably won't see a similar proposal under Part D, as CMS argued it is actually using some of the principles of Part D to inform their payment methodology in Part B. However, as America's Health Insurance Plans (AHIP) pointed out in their comments to CMS, this proposal would likely have some significant downstream effects on MA and Part D plans. AHIP noted the historical tendency of a reduction on pharmaceutical prices in one market segment to lead to cost-shifting practices by manufacturers, such as setting higher prices for new drugs and higher drug price increases for existing drugs. MA and Part D also lose out because they lack the flexibilities of the new value-based tools proposed under Phase II that could also benefit MA and Part D plans. The rollout of the new model could also the affect MA and Part D bid process for 2018, due to the cost-shifting effect of the proposal.
CMS has already noted it will seriously consider making changes to the proposal. For example, CMS announced it will re-examine whether certain types of practices would not be adequate enough to cover certain types of drugs — such as small rural oncology practices. We could also see CMS propose an alternative tiered approach instead of the ASP and add-on formula. CMS is also considering excluding the new oncology care model from this proposal. Despite these changes, questions as to the effect on the remaining Medicare drug programs remain.
Resouruces
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. Our broad array of services can assist you in post-audit remediation, implementation of best practices, PBM contracting and implementation, interim staffing, clinical process re-engineering, Star Ratings improvement, and claims and PDE assessment and adjustments. Visit our website to learn more >>
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What a Clinton Administration Could Mean for Government Health Programs
So the people spoke and we are heading for an epic cagematch smackdown general election between reality TV star Donald Trump and former Senator and Secretary of State Hillary Clinton. And you're asking, what's going to happen to Medicare, Medicaid and ObamaCare? The answer is plenty -- below the waterline and out in the states. Stakeholders will need to pay attention or get left behind.
First, the likely scenario is that Hillary is going to win this thing big. While other Republicans may have had a chance to capitalize on her high negatives with likely voters, nobody's negatives trump Trump's. He's the most unpopular major-party candidate since polling began. Most polls have him losing by double digits in November.
At this moment, Trump's likely to lose so bad that many down-ticket Republican Senate and House seats are now in play. So: Hillary in the White House, Democrats likely running the Senate again, and poor Speaker Paul Ryan trying to corral an even more radical, noisy and smaller Tea Party caucus in the House. The only people those guys hate more than President Obama are the Clintons. So betting on more gridlock is safe money. Little or nothing gets done in Congress except the bare minimum to keep government running.
That means most of what happens in Medicare, Medicaid and ObamaCare will occur "below the waterline" in Administrative policy, regulation, and guidance, or is driven by the states. Here's what that could look like:
- Medicare: the forced march to value-based payment across the program will continue. The recent MACRA rule makes it clear that a fundamental change to traditional Medicare is coming and that fee-for-service is dead. By the end of Hillary's term, a majority of Medicare dollars will be tied to provider performance. Medicare Advantage will continue its steady 5-7% annual growth and exceeding 25 million enrollees in 2020. But CMS raises the bar through a rapidly-maturing Star Ratings program and an aggressive compliance and auditing initiative carried over from Obama's last year in office. Regulations and guidance are pumped out in regular order, drafted by newly-emboldened career CMS staff and making the program a laboratory of continuing performance improvement with claws and teeth.
- Medicaid: on the heels of the biggest regulation in 12 years, Medicaid converges more than ever with Medicare Advantage and ObamaCare, but also goes down some very strange alleys. With Obama out of office, several more red states like OK and TN finally take the Medicaid expansion deal from the Affordable Care Act. But with it they insist on "conservative principles" like work requirements and drug testing that dampen coverage and introduce new complexities to the program. At the same time, blue and red states alike flood CMS with new home and community-based services waivers to force dual eligibles into health plans and implement managed long-term care programs.
- ObamaCare and health insurance exchanges: health plans in the public exchanges continue a market correction and shakeout for another two years. During that time, CMS issues even more regulations dove-tailing exchange operations with Medicare Advantage rules, and several states currently running their own marketplaces like CO revert to healthcare.gov.
Health plans and other stakeholders in these programs will need to pay more attention than ever to stay ahead as government solidifies its role as their biggest customer. These are changes that won't necessarily be splashed across major media, but rather in trade rags and expert blogs. The only thing that's certain: it won't be dull.
Resources:
The Centers for Medicare & Medicaid Services (CMS) issued the final Medicaid "mega-rule," a huge regulation that makes changes to every part of the current managed care rules. Read more >>
Under the provisions of the 2015 Medicare Access and CHIP Reauthorization Act (MACRA), physicians and other practitioners will face a Hobson's choice: live with a more aggressive risk-based adjustment to payments or join forces with an alternative delivery model, like an Accountable Care Organization (ACO), that is taking risk. Read the full article >>
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50/50 Just Won't Cut It — You Have to Commit 100%. The Top 5 Components for Successful, Compliant, Committed Operations
If you weren't able to make it to the Gorman Health Group 2016 Forum this year, you missed a dynamic time. More than just relevant topics, it included engaged participants who added a wealth of depth to our discussions. The topic garnering a lot of audience participation was "Can Operational Efficiencies and Compliance Co-Exist?" The struggle to align the two is real and takes constant, diligent effort, but the success it can create is priceless.
I told a story about a recent vacation involving a shark swimming in the surf. At one point it started swimming towards a father and son. Those of us on the pier were yelling to warn the man to leave the water, but he couldn't hear us. It wasn't until the people on the beach carried the message to the man that they got out of the water. Oftentimes we rely on the Compliance Department to carry the weight of maintaining compliance, but like the people on the pier, that message only goes so far. To be effective and make a real change, the message has to be embraced by everyone in order to make a real difference.
Here are the five critical points to ensure operations entwines compliance in its core:
- Don't Ignore the Human Factor — Our employees are the most critical factors in our department's productivity and compliance. Make sure our employees are well trained on not only the technical components of the job but on the critical compliance requirements as well. Employee engagement, like member engagement, is critical to success. Our employees want to do a good job, but sometimes they don't fully understand all that success entails.
- Know the "Why" behind an Action — What vision have you imparted to your staff? Are they just keying in applications, or are they setting up and welcoming members into your plan? Do your employees think compliance is an obstacle to be circumvented or a process to be embraced? Making that transition occurs by showing the "why" behind the action. How does what they do, both individually and as a department, impact our members? What is the logic behind why the Centers for Medicare & Medicaid Services (CMS) requires that activity? What they do is important, and making sure they understand all the reasons why makes your vision their vision.
- Have the Right Tools — Manual work-arounds and systems that have been duct taped to manage Medicare Advantage and Part D cause most of us the greatest headaches and compliance failures. There is no magic wand to resolve this—it takes diligence, documentation, and prioritization on a continual basis to raise up the next critical system needing to be resolved. Have your list of things needing to be fixed, the additional costs associated with the status quo, and the member impact ready and on the enhancement list.
- Provide Measurable Results of Success and Failure — Have a highly-visible way to measure individual and team success and failure. Successes should be celebrated. Share the successes and bring the feedback to your team. Failures should be evaluated—it isn't about the "who did it" but about the "why it happened." Everyone should be focused on mitigation. One of the items the audience discussed is ensuring you eliminate a culture of fear so staff is engaged in reporting non-compliance so it can be addressed. When non-compliance is identified, embrace it and thank those who raised the issue. Let them know how this positively impacted the department, company, and members.
- Manage Up — Sometimes we in management are the biggest barriers to compliant operations. We look at the production numbers and don't focus on the compliance measurements. We only give senior management what they ask for—it is our job to make sure the critical metrics and measurements go up to senior management. They often don't know the right questions to ask or measurements to review, and it is our job to bring this forward—it protects the company and our members.
We all have a part to play to ensure efficient, compliant operations are in place for our members. It takes 100% commitment to make sure the vision is carried forward. At Gorman Health Group, we know how important it is to link compliance and productivity. We are available to join with you to ensure that vision is firmly established in your organization. Please contact me directly at jbillman@ghgadvisors.com.
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At Gorman Health Group, we maintain the country's largest staff of senior operations consultants. Our team assists dozens of health plans every year in scrubbing their member data and can translate your business strategies into practical, efficient and rigorous work processes with the highest degree of compliance and accountability. Visit our website to learn more >>
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Takeaways from the Gorman Health Group 2016 Client Forum
The Gorman Health Group 2016 Forum concluded last week with over 200 of our closest clients and partners. There was great news and rough news, so here are a few takeaways:
- The playing field of government programs continues to expand rapidly, with improving revenue outlook across the board:
- We're sticking by our projections of over 29 million Medicare Advantage (MA) enrollees by 2023, driven by more positive rate trends and a plan-friendly baby boomer tsunami underway.
- Six to eight more states expand Medicaid — once President Obama leaves office.
- Significant enrollment gains for dual eligibles as home and community-based services (HCBS) waivers and managed long-term services and supports (MLTSS) initiatives become the new normal. We expect dual eligible special needs plan (D-SNP) enrollment to double and exceed 4 million by 2019.
- Rising ObamaCare enrollment, albeit slowing and below projections, as more difficult-to-reach populations remain outside coverage.
- During the Forum, United announced its departures from most ObamaCare Marketplaces. We characterized the news as a nothingburger in terms of enrollment or market impact but huge symbolically and politically. We expect another two to three messy years sorting out the pricing and finances of the Marketplace business, with membership reconciliation and cleanup of membership discrepancies front of mind for issuers.
- Risk Adjustment Data Validation (RADV) audits will begin to be conducted in MA — 2016-2018 will be the first time we see plans prosecuted under the False Claims Act and hundreds of millions clawed back by the Centers for Medicare & Medicaid Services (CMS) for unsubstantiated codes submitted for higher payments.
- Clinical and pharmacy data integration and strong provider partnerships around person-centered care were clear priorities in medical management, Star Ratings improvement, and Pharmacy Benefit Manager (PBM) oversight.
- The Star Ratings system of performance-based payment drives the payer and provider markets. This year will be the first year where plans below 3 stars are terminated. It's also when another 180+ MA plans will be scored for the first time, diluting ratings for existing plans, especially those at 4+ stars and denying many their bonuses and rebates in what promises to be an ugly "October Surprise."
- The turbulent Presidential elections will likely be won by Hillary Clinton, promising continued gridlock with a likely weakened and more polarized Congress. This means CMS will increasingly fight out policy changes "below the waterline" in subregulatory guidance and enforcement, where politicians are less likely to intervene. That means more surprises for plans not paying attention.
- Appeals and grievances and pharmacy benefit management vendor performance remain the #1, 2, and 3 regulatory infractions in MA and integration of long-term care and supports and services the leading challenge facing Medicaid health plans.
- CMS is on pace for its most aggressive enforcement year ever, with over a dozen actions taken against plans this year already.
As we've said since the passage of the Affordable Care Act, we are now in the Golden Age of government-sponsored health programs, and the opportunities and challenges that come with this shift have never been greater. Our clients went home with a clear grasp of both, and we are thrilled so many joined us this year.
Resources
Our distinguished team of experts collaborated to provide our interpretation of this announcement and the key features that will have the greatest impact on the industry, emphasizing core business functions in Risk Adjustment, Provider Network, Quality, Compliance, Pharmacy, and Data Integrity. Download our full Summary & Analysis of the Final Rate Announcement & Final Call Letter >>
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CMS Largely Holds Firm on Most Proposed MA Payment & Policy Changes for 2017
On April 4th, the Centers for Medicare & Medicaid Services (CMS) issued the Final Notice of Methodological Changes for Calendar Year (CY) 2017 for Medicare Advantage (MA) Capitation Rates, Part C and Part D Payment Policies, and 2017 Call Letter. This is the final notice of changes in rates of payment and overall policy.
CMS finalized most of its proposals from the Advance Notice and Call Letter, however did make some notable changes:
- Rates and Trend: The final trend is 3.12% inclusive of underlying trend and prior period adjustments. The underlying trend was slightly higher than estimated while the correction to the prior period was lower than expected (0.14%), so in the end, the trend nets out close to the original estimate. CMS estimates a 0.85% increase of all-in rates.
- Normalization Factor: CMS notes a technical error which affected the proposed normalization factors in the Draft Call Letter. The normalization factor was updated from 0.993 to 0.998.
- Encounter Data: CMS will increase the use of encounter data-based risk scores to 25% in 2017, instead of 50% as proposed in the Draft Call Letter.
- Employer Group Waiver Plans (EGWP): CMS is finalizing its new policy for calculating EGWP county payment rates, with two modifications. First, CMS will blend individual market plan bids and EGWP bids from 2016 for 2017, in order to allow for a two year transition period. Second, CMS will use prior payment year information to calculate base payment amounts in order to release the final EGWP payment rates in the Rate Announcement instead of August as previously expected. It is also important to note that while the methodology waives the bidding requirements, MA EGWPs must still submit plan benefit package and formulary in accordance to the 2017 Final Call Letter.
- Star Reduction Policy: As noted in a March HPMS memo, CMS is suspending the reduction of the overall and summary Star Ratings of contracts that are under sanction, while CMS re-evaluates the impact of sanctions, audits, and CMPs on the Star Ratings. CMS plans to describe the new proposals in Fall 2016.
- Low rated plans to be terminated: Although CMS will continue with termination of plans falling below 3 stars, CMS announced it may ‘stay' a termination, including notification of beneficiaries, if the organization holding the poorly-rated contract is prepared to consolidate that contract into a higher rated contract during the bid cycle for the upcoming plan year.
The following major proposals were finalized as proposed:
- Risk Model for Dual Eligibles: Although the proposed methodology will be implemented, data will be updated, so the original estimated rate impact by category may change. Despite the new rate impact, organizations should still expect increase in payments for non-institutional full-duals and reduced payments for all other categories. CMS estimates a net impact on rates of -0.6%.
- Stars dual Interim Adjustment: CMS is moving forward with its proposal to apply the Categorical Adjustment Index factor to overall, Part C Summary and Part D Summary Ratings as an interim solution to account for the Star Ratings impact of dual-eligible and disabled beneficiaries.
- Opioid Overutilization: CMS is finalizing its proposal to combat opioid overutilization by implementing new edits to prevent overutilization at the Point of Sale (POS). CMS expects sponsors to implement either a soft edit or hard edit, or use both as originally proposed in the draft Call Letter, and work toward at minimum a hard edit in 2018.
Compliance Updates:
- CMS again reminds Part D sponsors that it is stepping up enforcement actions on coverage disputes and complaints, the leading noncompliance issue for plans.
- Plans failing financial audits conducted on one-third audits will now also be subject to sanctions and civil money penalties
- CMS is ramping up audits and enforcement actions in network adequacy, provider directory accuracy, and medication therapy management programs.
These are just the major highlights of from CMS' Final Notice and Call Letter. Stay tuned for Gorman Health Group's (GHG's) industry experts summary and analysis of the final changes for 2017, coming out shortly. questions about the summary? Contact us to start a dialogue.
Resources
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