To File or Not To File, That Is the Question

January 27, 2016
|In Compliance
|By GHG Advisors

We’ve made it clear through this blog the Centers for Medicare & Medicaid Services (CMS) is throwing down the gauntlet in terms of ensuring Medicare Advantage provider networks are adequate. The biggest change to the 2017 application process supports this initiative. For Service Area Expansions, CMS is requiring current service area network data at the contract level in addition to the pending service area data. Previously, CMS requested only those providers supporting the pending counties. Applicants took to the CMS User Calls to ask clarifying questions about this requirement, including a number of “what if” questions, indicating that applicants either know they have unknowns in their networks, or they know how their network fares and they want to know the consequences. In addition to some provider network documentation changes, here are some other notable changes to the application process:

  • Quality Improvement Plan and Crosswalk are no longer required at the time of submission.
  • If a contract of the applicant has been terminated or non-renewed over the past two years, a Two-Year Prohibition Waiver Request is required.
  • Additional required contacts have been added.

Here are some key dates to keep in mind:

  • User Calls took place on January 13 and 20. Current and pending Sponsor applicants are encouraged to review the CMS Part C & D User Call recordings.
  • The application deadline is February 17, 2016, at 8:00 PM Eastern time.
  • Part C deficiency notices will be sent mid-March.
  • Part D deficiency notices will be sent late March.
  •  Part C and Part D Notices of Intent to Deny or Approve will be sent late April.
  • Requests to drop counties are due May 20.
  • Part C and Part D Conditional Approvals or Denials will be sent late May.

Additional important dates have been communicated in the Part C and Part D application materials and in the User Call presentations. Something CMS has made clear again this year is that applicants should review all instructions provided, and reach out with questions, as there are no exceptions to the filing deadline. A well-prepared applicant will target for an early submission date so as not to risk getting caught up in a bottleneck of uploads. If you haven’t done so already, get ready and start your engines!

 

Resources

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