CMS 2011 Spring Conference Wrap-Up

The CMS 2011 Spring Conference has officially wrapped up, and once again a large amount of information came directly from CMS on the state of the market, what their expectations are and what plans need to do to succeed in the new world of healthcare. As is customary, Jonathan Blum, Deputy Administrator and Director of CMS, had the keynote speech. 

Mr. Blum spoke about the 2012 CMS Priorities for the Medicare Part C and Part D Programs and beyond. CMS’s focus is on the following three items:

1. Consistency
2. Quality Improvement
3. Continued focus on Compliance

Consistency
CMS’s view of consistency means policy consistency. Simplifying programs, benefits and plan choices for beneficiaries; making navigation of the Part C & D programs easier for beneficiaries overall. CMS has a great deal of policy to implement via the Affordable Care Act, so they are seeking to allow systems and plans time to catch up by holding steady with policy issuance.

Quality Improvement

The 5 Star Bonus Payment System signals that CMS cares about quality, improving scores and rewarding good plans.  Ratings are provided as a consumer tool and payment mechanism.  As such, in 2012, 5 Star Plans will be allowed to market enrollment year round; while plans with 2 Stars consistently for 3 or more years will not be allowed to offer products to beneficiaries. Overall growth of 7% has been recognized in Medicare Advantage for 2011; this growth is even faster for 4 Star and higher plans. Plans are focused on improving ratings so beneficiaries gravitate to their plans.

Continued focus on ComplianceCMS has a heightened focus on compliance, audits, and performance. This can be seen in the way 2010 audits were conducted. Several overall trends appeared during the audits that all plans should take note of. The areas consisted of Part D Formularies, Coverage Determinations, Grievances, and Enrollment & Disenrollment Processes.

In addition, Mr. Blum stated that plans should understand their business better than CMS.  They should see and identify trends and issues before CMS. Understanding why their beneficiaries are calling is critical to correcting issues immediately. The top area of concern noted in the audit findings centered on oversight of a plan’s Pharmacy Benefits Manager (PBM). While CMS understands this is a delegated role the plan must remember they are ultimately responsible to the member and CMS to ensure their enrollees receive their medications. The oversight of the PBM must be conducted on a daily basis to avoid issues and ensure beneficiaries receive their medications at point of sale. Special attention should be paid to protected classes and transition of medications; multiple problems were cited in these areas. Proper and timely processing of coverage determinations and grievances is critical to remain in compliance. Also, plans must ensure their enrollment and disenrollment processes are working fluently. Take the time to build internal controls and workflow processes to avoid issues later down the road.

Overall, CMS is focusing on becoming more forthright. Compliance is of utmost importance.  Better Compliance + Better Performance = Higher Plan Reimbursement.  As the Medicare program continues to grow and expand the plans that do well will receive more members.

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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 Pamela.Argeris@merrillcorp.com.

Health Reform Legislation Threatens Mini-Med Plans

If there has been one clear victim of the new health plan regulations, Mini-Med Plans are it. Last year when the new MLR percentages became reality, hundreds of Mini-Meds began seeking alternative measures to survive. HHS has provided a solution for 1,040 such plans. Out of all the Mini-Med Plans that applied, 94% have been granted a waiver, allowing the plans to be considered exempt from the new law. The exemption lasts only for one year, but is renewable until the full weight of the reform falls in 2014.

The waivers are required because the Mini-Med Plans, which provide care for over 2.6 million people, do not meet the minimum annual dollar limit on essential benefits as outlined in the reform legislation. This limit starts at $750,000 in 2011, increasing to $2 million in 2013. By 2014, the law states that there is to be no annual limit on essential benefits.

Mini-Med Plans cater to low-income or part-time workers, who often do not qualify for more expensive plans. Unless the reform legislation is re-written to account for these smaller providers, 2014 will see the end of Mini-Meds, and those employees will be forcefully folded into the government-created health exchange planned for 2014.

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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 Pamela.Argeris@merrillcorp.com.

Clarity of Health Reform

The debate rages on regarding health reform and the focus has now shifted to the constitutionality of the legislation. A Virginia judge ruled the individual mandate was unconstitutional and a Florida judge ruled the entire legislation was unconstitutional. This has sparked the 26 states included in the fight against the health reform legislation to withhold from implementing the act. 

Such states as Alaska have openly commented they will not enact the legislation but begin developing their own plans for health reform within their state. Gov. Sean Parnell said the state would pursue lawful, market-based solutions of its own. That includes planning for a health insurance exchange, meant to offer a choice of health plans.

This action compelled the White House to quickly respond stating while the Virginia and Florida judge have sited unconstitutionality of the law the law must not be upheld and implementation must continue. 

The main theme cited was the cost savings associated with the Medicare payment reform on 100 million Medicare claims that are processed each month. As the constitutionality of health reform continues to be at the forefront it appears only a ruling by the Supreme Court can conclude the acts fate.

For more information, read the Associated Press article on the topic here and to learn more via webinar, click here.

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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 Pamela.Argeris@merrillcorp.com.

HHS, IT Infrastructure and Health Insurance Exchanges

Last week, HHS announced a new initiative that will provide competitive funding opportunities for states to design and initiate IT infrastructures that will be necessary for the operation of Health Insurance Exchanges. Because these Exchanges will need to be designed to present a large number of individuals and small businesses with affordable health care options by 2014, new and advanced IT systems will be necessary well before then.

Exchanges, as we know, will provide a form of one-stop shopping for individuals and small businesses, with interested parties being able to examine, select, and enroll in one of many available plans offered at competitive, affordable prices. However, while many are focused and debating the policy aspect of this initiative, what gets lost is the IT infrastructure that will need to be constructed in order to make this (or any) end goal possible. The infrastructure will need to be well thought out and be based on several best practice examples (especially in the areas of simplicity and approachablity) in order to allow the Exchanges to operate like other similar consumer industry sites.

To assist with this aspect, states can apply, through HHS, for “Early Innovator Grants.” The grants will provide states with the capital to get a head start on building these necessary infrastructure models. States are to be chosen based on their current efforts toward consumer-friendly IT infrastructure, as well as their leadership in cost-effective solutions.

The first round of winners will be announced before February 15^th, 2011, and will be followed by additional award announcements which all states – including those that already received funding – will be eligible to receive.

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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 Pamela.Argeris@merrillcorp.com.