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The Voice of Regan Pennypacker
OK, so maybe reprieve is not the right word, since according to Google it is defined as “a cancellation or postponement of a punishment”. If you consider a deadline a punishment, then I suppose this is a reprieve, but I digress.
This will be the title of my instructional pamphlet that I envision sitting in a doctor’s office, among other great pamphlets such as “Talking to Your Kids about Drugs” and “Depression: Not Just a Hole in the Ground”.
As AEP comes to a close on December 7, we are well into the time that organizations need to make sure that new members receive all of their required materials, including their identification cards. Having the annual election stretch to December 31 in the past was certainly to an organization’s advantage from a sales perspective, but it was an operational challenge when it came to ensuring those late applicants had access to services on day one.
Who saw last night’s presidential debate in Denver? Certainly there is a great deal of water cooler discussion going on today. Something that irked me was the continual reference to the fact that Medicare would continue to be available for “seniors”. Anyone working in the Medicare Advantage arena (whether it’s in Medical Management, Sales, Customer Service, you name it) knows that Medicare is not just for seniors. The Marketing guidelines even prohibit targeted marketing in this regard, i.e. implying a plan is available only to seniors as opposed to all Medicare beneficiaries. In fact, the list of under-65 recipients who qualify is as long as the list of over-65 qualifications.
According to the Department of Health and Human Services (HHS), Medicare Advantage (MA) enrollment is anticipated to grow 11 percent. Regardless of the politics behind the message, more beneficiaries than ever will be enrolled in MA products. Most organizations cannot keep up with all of CMS’ requirements. As evidenced in their best practice reviews of 5-star plans, no plan is perfect. Common findings included improper formulary administration, denial of transition fills, and lack of an effective monitoring and auditing system. These findings have a high impact on MA enrollees.
It seems like only yesterday that I was submitting comments in response to CMS’ draft chapter 13. It was, in fact, way back in April of 2007, when I was a budding young compliance analyst determined to keep a plan on the right track.
Ongoing monitoring and auditing is a widespread challenge, but they are must-dos according to CMS’ compliance program requirements. You have some tools, but not enough to capture the full picture. Responsibilities are spread out between departments and delegated entities. Is the risk assessment just a matter of asking for a list of risks, or is it simply a review of the OIG work plan? It’s just not enough. Where does your sanity check fall on your annual risk assessment, let alone your daily planner?