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MedHOK Compliance Insights December 2014 – Important Reminders, Reporting of Emergency Part C&D Issues, and Physician Medicare Enrollment File

IMPORTANT REMINDERS

2015 Medicare CAHPS® Survey – Sponsors with 600 or more enrollees as of July 1, 2014 are required to contract with CMS-approved MA & PDP CAHPS survey vendors to conduct data collection. This includes Medicare-Medicaid Plans with 600 or more enrollees as of July 1, 2014. Sponsors must inform CMS of the vendor that will be submitting data on their behalf no later than January 2, 2015. A list of approved vendors and the vendor authorization form can be found on the MA & PDP CAHPS website at http://www.ma-pdpcahps.org

Use the revised Medicare Part D Medication Therapy Management (MTM) Program Standardized Format, Form CMS-10396 (07/14), which must be provided to beneficiaries after a CMR. The form is effective January 1, 2015.

Reporting of Emergency Part C & D Issues for January 1 – 4, 2015

As in previous years, CMS is establishing a Part C & D operations monitoring program for January 1, 2015 through January 4, 2015.

Non-technical significant emergency issues should be reported via email to both drugbenefitimpl@cms.hhs.gov and your CMS Account Manager. Significant emergency issues are defined as significant Part C & D delivery issues that impact access to service for 100 or more beneficiaries. The problem should be reported even if it was time-limited but lasted an hour or longer (e.g., claims processing or call center was temporarily disrupted).

Compliance actions may be taken in instances where plan sponsors fail to report issues. Beneficiary-specific issues should be reported and resolved through the normal casework procedure and not reported through this process.

Physician Medicare Enrollment Requirement – CMS Provides File to Prepare for Enforcement

Contract Year 2015 Policy and Technical Changes to the Medicare Advantage and the Medicare Prescription Drug Benefit includes a rule which requires physicians and, when applicable, other eligible professionals who write prescriptions for Part D drugs to be enrolled in Medicare in an approved status or to have a valid opt-out affidavit on file for their prescriptions to be covered under Part D.

The final regulation stated that the effective date for this requirement would be June 1, 2015. However, CMS is announcing that it will delay enforcement until December 1, 2015. Nevertheless, prescribers of Part D drugs must submit their Medicare enrollment applications or opt-out affidavits to their Medicare Administrative Contractors (MACs) by June 1, 2015, or earlier, to ensure that MACs have sufficient time to process the applications or opt out affidavits and avoid their patients’ prescription drug claims from being denied by their Part D plans beginning December 1, 2015.

In an effort to prepare prescribers and Part D sponsors for the enforcement date, CMS has made an enrollment file that identifies physicians and eligible professionals who are enrolled in Medicare in an approved status or have a valid opt-out affidavit on file with a MAC. The first iteration of the enrollment file is now available.

CY 2016 Model of Care Submission Training

On December 17, 2014 CMS issued a memo providing information about upcoming contract year (CY) 2016 Model of Care (MOC) submission training and technical assistance calls for Medicare Advantage organizations (MAOs) that will offer a Special Needs Plan (SNP) in CY2016. These calls will provide MAOs with information about the MOC submission process. MOC submissions are due February 18, 2015.

SNPs operating under a 1-year MOC approval, SNPs with multi-year MOC approvals that expire December 31, 2015, and SNPs requesting service area expansions will be required to submit a new MOC in February 2015.

These trainings will be conducted via WebEx as outlined below:

Training on MOC Elements 1 – 2:

Tuesday, January 13, 2015, 3:00 – 4:30 EST
Participant Dial-In Information: (866) 628-7188
Conference Id#: 40357959 WebEx Information:
Host: Delia Ponce
Password: Approval2015

Training on MOC Elements 3 – 4:
Thursday, January 15, 2015 3:00 – 4:30 EST

Participant Dial-In Information: (866) 628-7188
Conference Id#: 403614962
WebEx Information:
Host: Delia Ponce
Location: https://ncqaevents.webex.com/ncqaevents
Password Approval2015

Technical Assistance Training

Tuesday, February 3, 2015, 3:00 – 4:30 EST
Participant Dial-In Information: (866) 628-7188
Conference Id#: 40363471

Technical Assistance Training
Thursday, April 23 2015, 3:00 – 4:30 EST
Participant Dial-In Information: (866) 628-7188
Conference Id#: 40389520

If you any questions, please contact Susan Radke at 410-786-4450.

Incarceration Policy System Changes

Contract Year 2015 Policy and Technical Changes to the Medicare Advantage and the Medicare Prescription Drug Benefit Program included a provision outlining the ineligibility of enrollment into Medicare Advantage, Part D, and cost plans for confirmed incarcerated individuals (79 FR 29914).

While the applicability date for this provision is listed as January 1, 2015, CMS is in the process of making systems changes to provide plans the confirmed incarceration status of beneficiaries. CMS will be providing sub-regulatory guidance, including information regarding transaction codes and adjustments to model notices, in advance of plans’ responsibilities for determining eligibility or effectuating involuntary disenrollments based on confirmed incarceration.

Until the updated guidance has been issued, plans are expected to follow the existing guidance currently in Chapter 2 and Chapter 17, Subchapter D of the Medicare Managed Care Manual and Chapter 3 of the Medicare Prescription Drug Benefit Manual regarding these topics.

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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