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September 2017 Compliance Insights

September 2017 Compliance Insights

IMPORTANT REMINDERS

September 7, 2017 2017 MA & PDP Fall Conference & Webcast

Event Materials can be found on the Compliance Training, Education & Outreach (CTEO) page.

Beginning no later than October 1, 2017 All plans offering Part D must use the revised, OMB-approved standardized Notice of Denial of Medicare Part D Prescription Drug Coverage. The revised notice must be provided to Part D enrollees when a plan issues a fully or partially adverse coverage determination. The notice and accompanying instructions are posted on the CMS Medicare Prescription Drug Appeals & Grievances webpage (under “Plan Sponsor Notices and Other Documents”)

On August 30, 2017 CMS released a memo and provided a link regarding Frequently Asked Questions Regarding Accessible Communications for Individuals with Disabilities

On August 18, 2017 CMS issued a memo to notify Medicare Advantage Organizations (MAOs) of changes to the Quality Improvement Project (QIP) and Chronic Care Improvement Program (CCIP) requirements. CMS will release separate guidance for Medicare-Medicaid Plans (MMPs).

COMPLIANCE NEWS

Health Plan Management System (HPMS) Video Presentation

On August 3, 2017, HPMS announced the release of a new “Welcome to the Health Plan Management System (HPMS)” video presentation on the CMS YouTube channel.

This presentation provides a high-level overview of HPMS, covering the following areas: scope of the Medicare Advantage (MA) and Prescription Drug (Part D) business areas supported by the system, HPMS list serv and news archive, components of the user interface common look and feel, users of the system, and help resources.

The video can be accessed via the CMS YouTube channel or directly at https://youtu.be/5mLfgS_xA1g.

NCQA Updates Quality Measures for HEDIS 2018

NCQA published the initial Tech Specs for HEDIS 2018. On July 19, 2017, NCQA presented a webinar where they outlined this year’s changes to the Tech Specs. If you missed it, you can re-play the webinar.

Seven new measures have been added; one hybrid measure, 3 admin only measures, and 3 ECDS (Optional) measures. Additionally, there were changes made to four existing measures and two broader changes that impact multiple measures. Below is a brief summary with a few highlights. Please note that MedHOK’s NCQA Certified HEDIS engine will be updated to reflect these changes for the HEDIS 2018 season.

New Measures:

Transitions of Care (TRC) – Hybrid: Percentage of inpatient discharges for Medicare members.

  • Notification of Inpatient Admission (Administrative is not available for this measure)
  • Receipt of Discharge Information (Administrative is not available for this measure)
  • Patient Engagement After Inpatient Discharge
  • Medication Reconciliation Post-Discharge

This is the only new hybrid measure that is being introduced. It is closely related to the existing Medication Reconciliation Post-Discharge (MRP) measure. In fact, MRP is one of the four indicators or sub-measures for this new measure. The existing MRP measure has not yet been retired, but the good news is that you can use the same denominator for these two measures. Please note that the first two indicators can only be captured via Medical Record Review and not through administrative data.

Use of Opioids at High Dosage (UOD) – Admin: The rate per 1000 of health plan members who receive long term (prescriptions of >= 15 days) opioids at high dosage (avg morphine equivalent dose >120mg)

Use of Opioids from Multiple Providers (UOP) – Admin: The rate per 1000 of health plan members who receive opioids from multiple prescribers (4 or more) and/or multiple pharmacies (4 or more).

Depression Screening and Follow-Up for Adolescents and Adults (DSF) – ECDS: The percentage of health plan members 12 years and older who were screened for clinical depression and, if screened positive, received appropriate follow-up care.

Unhealthy Alcohol Use Screening and Follow-Up (ASF) – ECDS: The percentage of health plan members who were screened for unhealthy alcohol use and, if screened positive, received appropriate follow-up care within two months.

Pneumococcal Vaccination Coverage for Older Adults (PVC) – ECDS: The percentage of health plan members 65 years and older who received the recommended series of pneumococcal vaccines.

Changes to Four Existing Measures

Immunizations for Adolescents (IMA): For HPV, a two-dose, rather than a three dose vaccination schedule in now permitted.

Breast Cancer Screening (BCS): Digital Breast Tomosynthesis (DBT) has been added to the list of acceptable tests for breast cancer screening.

Initiation and Engagement of Alcohol and Other Drug Abuse or Dependence Treatment (IET).

  • Medication-assisted treatment (MAT) and Telehealth have been added as appropriate treatment options
  • Alcohol, Opioid, and Other Drug Dependence have been added as subgroups for reporting rate stratification
  • The Engagement time-frame has been extended from 30 to 34 days

Identification of Alcohol and Other Drug Services (AOD):

  • Medication-assisted treatment (MAT) has been added as an appropriate treatment options
  • Alcohol, Opioid, and Other Drug Dependence have been added as subgroups for reporting rate stratification
  • Outpatient, ED and Telehealth services have been separated for more granular reporting

Plan All-Cause Re-admissions (PCR): Extended to the Medicaid population. This measure now applies to all three lines of business (Medicare, Commercial and Medicaid).

Changes impacting multiple measures:

Telehealth for Behavioral Health Measures: NCQA introduced telehealth in seven behavioral health measures for HEDIS 2018.

Institutional Care Setting Exclusions: Medicare members enrolled in Institutional Special Needs Plans (I-SNPs) or who live long-term in institutional care settings are now excluded from the following measures:

  • Breast Cancer Screening (BCS)
  • Colorectal Cancer Screening (COL)
  • Osteoporosis Management in Women Who Had a Fracture (OMW)
  • Controlling High Blood Pressure (CBP)

MedHOK Strategic Insights Blog

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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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