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April 2018 Compliance Newsletter

April 2018 Compliance Newsletter

Welcome to the April 2018 MedHOK Compliance Newsletter. This issue provides essential compliance, reporting and security announcements affecting your business.

IMPORTANT REMINDERS

Now Open! Registration is now open for the MA & PDP Spring Conference and for the Audit and Enforcement Conference!

May 9, 2018 Medicare Advantage and Prescription Drug Plan Spring Conference.

Audit Engagement Letters – CMS began sending audit engagement letters in March. Audit notifications will continue through September.


COMPLIANCE NEWS

CTM Module and SOP Updated

On March 9, 2018, CMS released updated Complaints Tracking Module (CTM) standard operating procedures via an HPMS memo:

  • CMS will be deploying technical system enhancements to the Complaints Tracking Module (CTM) effective April 16, 2018.
  • CMS confirmed the CTM will be modified to capture either the MBI or HICN for a beneficiary’s complaint. CMS will primarily record the HICN in the CTM until shortly after all new Medicare cards have been mailed.
  • An updated Plan Download File layout associated with the next release will be found in the “Documentation” section in the CTM on 4/16/2018. The only change from the current layout is the Zip Code field will be modified to capture up to 10 characters.
  • CMS also updated the CTM Plan SOP to provide clarifying guidance.

Click here to read the HPMS memo and updated CTM SOP.

CMS Clarifies MBI Directions This Week

On March 28, 2018, CMS clarified HICN and MBI can be used interchangeably during the MBI transition period for both letters and IRE case submissions. CMS updated its main MBI page to state:

*Updated* The HICN is now used on many standardized forms and letters. We’ll be revising these materials just for MBI use, but until they’re ready, plans should keeping (sic) using the forms they have with either the HICN or MBI as appropriate.”

Click here to see this statement in context on CMS’s website. Click here to review our full blog post.

Contract Year 2018 Monitoring of Medicare-Medicaid Plan Provider and Pharmacy Directories – Update

Per the HPMS memo released on March 15, 2018, CMS reports significant year over year improvements for MMP Provider and Pharmacy Directories. CMS did, however, identify, the need for additional improvement in the following areas:

  • Providing additional information on home infusion and long-term care (LTC) pharmacy
    services and how members can get more information.
  • Listing the counties serviced by home infusion and LTC pharmacies within pharmacy
    listings or inclusion of a disclaimer.
  • Including specific accommodations at the facility for individuals with physical
    disabilities (e.g., wide entry, wheelchair access, accessible exam rooms and tables).

In addition, while CMS noted some progress in several sampled directories indicating if a provider has completed cultural competence training, CMS sees opportunity for further improvement in fulfilling this requirement.

To reinforce ongoing burden reduction efforts and aid MMPs in preparing their CY 2019 directories, CMS will highlight process improvements, discuss lessons learned, and feature best practices in an upcoming webinar. CMS will reach out through Contract Management Teams in early April to determine MMP topics of interest and welcomes Plan’s ideas.

CMS expects to issue monitoring results letters by the end of March 2018 to each MMP whose directories were reviewed. Each letter will include the MMP’s raw score, improvement measure (if applicable), and final score for CY 2018, as well as a table of weights and descriptions of reviewed requirements and a clearly labeled summary of the specific elements reviewed.

Click here to review the HPMS memo titled ‘Contract Year 2018 Monitoring of Medicare-Medicaid Plan Provider and Pharmacy Directories’.

CY 2019 Formulary Reference File  Draft

On February 28, 2018, CMS Released the Draft CY 2019 Formulary Reference File. Click here to review the Formulary Reference File.

Reliability Testing of New Quality Measures for the PACE Program

The Centers for Medicare & Medicaid Services (CMS) and its contractor, Econometrica, Inc., are testing potential quality measures for the PACE program. Testing will occur between April and May 2018. Econometrica personnel may reach out to Plan contacts over the next several weeks to arrange testing and data collection. Any questions regarding the testing or recruitment process can be sent by email to PACEAdmin@EconometricaInc.com.

SECURITY NEWS

You have been called into a meeting to give your security approval for a new service or technology and you have not had time to review it or to do any research. Relax. With your arsenal of well written policies to help guide your decision-making, you can quickly assess the requirements at a high level and identify areas that will need a deeper dive.

Well-written policies and procedures that offer enough detail to guide day-to- day operations, set clear expectations for employees, and guard against liability issues that can save you time and money in the requirements gathering phase of a new project.

Development teams might not consider policies to be baseline requirements for IT projects; however, policies can provide the initial security requirements such as access controls, data encryption, secure coding guidelines. Referencing policies in requirements gather meetings and design documents can champion their usefulness for this purpose.

Reviewing your policies at least annually or more often to keep them up to date and relevant will ensure you have a useful resource during requirements gathering and design.

Marc Ryan

Marc S. Ryan serves as MedHOK’s Chief Strategy and Compliance Officer. During his career, Marc has served a number of health plans in executive-level regulatory, compliance, business development, and operations roles. He has launched and operated plans with Medicare, Medicaid, Commercial and Exchange lines of business. Marc was the Secretary of Policy and Management and State Budget Director of Connecticut, where he oversaw all aspects of state budgeting and management. In this role, Marc created the state’s Medicaid and SCHIP managed care programs and oversaw its state employee and retiree health plans. He also created the state’s long-term care continuum program. Marc was nominated by then HHS Secretary Tommy Thompson to serve on a panel of state program experts to advise CMS on aspects of Medicare Part D implementation. He also was nominated by Florida’s Medicaid Secretary to serve on the state’s Medicaid Reform advisory panel.

Marc graduated cum laude from the Edmund A. Walsh School of Foreign Service at Georgetown University with a Bachelor of Science in Foreign Service. He received a Master of Public Administration, specializing in local government management and managed healthcare, from the University of New Haven. He was inducted into Sigma Beta Delta, a national honor society for business, management, and administration.

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