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Did You Get Your Timeliness Monitoring Notice Yet?

Did You Get Your Timeliness Monitoring Notice Yet?

Back in mid-December, we told you to get ready for the return of Timeliness Monitoring in the Medicare Advantage and Part D programs. The first wave of notices did indeed go out this month. Some of our clients have submission deadlines this week.

As noted by the Centers for Medicare and Medicaid Services (CMS), monitoring will be conducted in three waves. Below is a re-publishing of our table from December showing what you can expect to submit in the coming months if you have not yet received your letter. That is unless you are one of the few lucky plans carved out, including most of those audited in 2017 as well as PACE plans, MMPs, and a few others.

You can access the Health Plan Management Systems (HPMS) Memo here.

Even as your chance of audit is increasing dramatically, timeliness monitoring, coupled with CMS’ IRE auto-forward and overturn monitoring, provides CMS annual insight into every plan’s compliance record. The submissions will test for case timeliness, as well as accurate IRE auto-forwarding. Plans get 15 business days for submission from the notice date. Also remember, the monitoring review covers all cases, whether conducted by the plan or delegated entities. Universes will be validated and then reviewed. Fines can be levied for both submission issues as well as findings. CMS will run a timeliness analysis on all validated universes and determine a timeliness rate for each case type. Additional submissions or a full audit could result from monitoring outcomes.

As we stated in December, there is much riding on timeliness monitoring and plans need to be ready. Plans should always be conducting monthly universe monitoring as well as quarterly mock audits. It needs to be part of your compliance routine. In addition to being mapped to CMS compliance requirements, MedHOK’s Pharmacy, Utilization Management, Appeals, Grievance and Care Management/Model of Care solutions all include on-demand CMS universe reports to aid in your monitoring, mock audits and submission efforts. To learn more, visit us online at www.MedHOK.com and see our Compliance page.

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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