The Voice of Regan Pennypacker

Regan Pennypacker

About Regan Pennypacker

Regan is Senior Vice President of Compliance Solutions at Gorman Health Group (GHG). She leads the Compliance Solutions practice, responsible for multidisciplinary projects such as Part C and Part D audits, new applications, marketing material reviews, risk assessments, and training engagements. As a member of this team, she has provided compliance direction and insight on industry best practices to dozens of GHG clients. Regan brings GHG clients 17 years of experience in the healthcare industry. Read more

To Everything There Is a Season: Marketing Materials

Regan Pennypacker

There is a season for every activity within your organization: one for bids, one for applications, one for data validation.  We are soon to come upon marketing material season, when a flurry of activity usually gets underway in Marketing Communications and Compliance Departments nationwide.  Here are three reasons to ramp up: Read more

Leave a comment | Share | |

Compliance Highlights of the CY 2017 Draft Call Letter

Regan Pennypacker

According to the Centers for Medicare & Medicaid Services (CMS), the Call Letter activities follow four major themes: improving bid review, decreasing costs, promoting creative benefit designs, and improving beneficiary protections. This means implementing creativity and doing more with less while enhancing the beneficiary experience.  To borrow from one of the earliest reality shows, this is the time when CMS stops being nice and starts getting real.  There are some of the key items of which your Compliance Department needs to be aware outlined below; however, it is not all inclusive and a thorough read of the document is required.

Read more

2 Comments | Share | |

This Is the Year to Get It Right

Regan Pennypacker

Five consecutive years of very similar audit protocol, continuous partnering with sponsors to identify improvements, and numerous best practice/common conditions memos. Where are you in audit readiness? Did you evaluate the items in the 2016 Readiness Checklist sent in November?  I will get back to that! In the meantime, the Centers for Medicare & Medicaid Services (CMS) has started sending audit letters, so we are aware of sponsors and Pharmacy Benefit Managers (PBMs) alike who are prioritizing CMS’ requests. Early bird catches the worm, am I right?  Presumably these plans have larger enrollment, since they will only be required to provide rejected claims for the one month of January.

Read more

Leave a comment | Share | |

To File or Not To File, That Is the Question

Regan Pennypacker

We’ve made it clear through this blog the Centers for Medicare & Medicaid Services (CMS) is throwing down the gauntlet in terms of ensuring Medicare Advantage provider networks are adequate. The biggest change to the 2017 application process supports this initiative. For Service Area Expansions, CMS is requiring current service area network data at the contract level in addition to the pending service area data. Previously, CMS requested only those providers supporting the pending counties. Applicants took to the CMS User Calls to ask clarifying questions about this requirement, including a number of “what if” questions, indicating that applicants either know they have unknowns in their networks, or they know how their network fares and they want to know the consequences. In addition to some provider network documentation changes, here are some other notable changes to the application process: Read more

Leave a comment | Share | |

Three Reasons Why Compliance Program Effectiveness Needs Evaluation Now

Regan Pennypacker

Happy New Year! It’s a time when your organization may be evaluating whether or not to submit a new application or a service area expansion. This may be when annual training kicks off once again. You may be reviewing attestations to determine which vendors need to provide you with new documentation.  And don’t forget to ensure the Claims Department has updated systems to reflect the current prompt payment interest rate.

Read more

Leave a comment | Share | |

CMS Clarifies Key Audit Terminology

Regan Pennypacker

Immediate Corrective Action Required (ICAR), Corrective Action Required (CAR), and Observation. These terms have become part of the vocabulary for Compliance specialists, auditors, analysts, managers, directors, and Compliance Officers who so often field questions from Operations. Let’s consider the following scenario: Compliance has just completed an internal audit of Claims Operations and has identified findings. This leads the Ops team to ask, “Are these findings CARs or ICARs?”

Read more

Leave a comment | Share | |

Evolution of Validation: Selecting an Independent Auditor

Regan Pennypacker

The Centers for Medicare & Medicaid Services (CMS) audit validation process has evolved over the past few years. Here is what you should know about the changes and how to best prepare to contract with an Independent Auditor, or IA.

Read more

Leave a comment | Share | |