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CMS Releases 2019 Plan Year Checklist

CMS Releases 2019 Plan Year Checklist

The Centers for Medicare and Medicaid Services (CMS) recently released its 2019 Plan Year Checklist. The checklist is not a substitute for understanding all of the myriad regulations, manuals and HPMS memos applicable to plans, but in some ways, it is the bible for successful plan operations. It is especially important for year one and young plans to closely scrutinize the checklist as it lays out each of the CMS partners plans they will need to integrate with to successfully carry out various reconciliations and other functions. The checklist applies to Medicare Advantage (MA), MA Part D (MA-PD), standalone Part D (PDP), Medicare-Medicaid Plans (MMP), and Cost Plans. For the first time it has combined the MMP checklist with the checklist previously issued for the other plan types.

In recent years, CMS has enhanced its new year planning oversight, especially for low-tenure plans.

CMS Account Managers have increasingly engaged in pre-Jan. 1 and post-Jan. 1 monitoring. Self-assessments are performed by plans and CMS expects that Account Managers are notified of risks and the need for technical assistance.

The checklist includes important information, emails and contacts regarding many areas, including these very important operations areas:

  • Precluded Providers (New)
  • Risk Adjustment Encounter Submissions (EDPS is a greater weight for 2019)
  • Part D PDE submissions
  • Any Willing Pharmacy requirements
  • Offshore Contracting
  • FDR Requirements
  • Customer Service Operations
  • Member Materials and Websites
  • Enrollment, including the new enrollment period changes. See our earlier blog here.
  • LIS and BAE requirements

See the checklist and various appendices below:

APPENDIX 1

APPENDIX 2

APPENDIX 3

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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