Wednesday, September 23, 2009

CMS Audits Aim For “Real Time” Reviews

In years past, the norm for CMS has always been to conduct retrospective audits – essentially a review of data from prior months’ (EX. CMS would arrive at the plan in October to review data from January through June).

Audits were primarily focused their efforts on universe pulls and standard operating procedures along with any known escalated events that came through their jurisdiction such as CTMs.

Moving forward CMS will be conducting audits of plans on a more "real time" basis. They are conducting more "focused" audits and they are keeping a tight view of all plan CTMs and their occurrences.

Also, MA plans are now directed to report more in-depth information to CMS beginning with HEDIS and other metrics. With this increased scrutiny of plans and Medicare Improvements for Patients and Providers Act's arrival in 2008, the theme of tighter monitoring continues to resonate throughout regulation for 2010.

As such, better procedures and business processes are no longer discussion points, but key elements in maintaining quality and compliance (see: The 2010 Call Letter, Marketing Guidelines, and Enrollment and Dis-enrollment Guidance).

As with any guidance and changes from CMS, the first step is indentifying what’s new, then moving forward with an analysis of how it will change your business; what it could add, change or remove for your processes.

Pam Argeris is a thought leader in the Healthcare Industry and possesses extensive, hands-on experience with CMS compliance, and multiple regulatory bodies such as NCQA, JACHO, and DOI. In her role at Merrill Corp., Pam focuses on developing solutions for compliance and quality assurance, delivered in a cost effective manner to improve beneficiary and prospect communications. You can contact Pam at

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