While we are all in the throes of Annual Enrollment Period (AEP), Madena is looking to support you by dedicating a newsletter to upcoming critical activities that can easily be overlooked during this busy time.
Have you reached out to your members potentially losing LIS based upon the October file from CMS? We recommend creating a checklist to make sure your organization covers all the necessary steps from now through year-end.
In October, CMS issued a memo regarding the 2020 Timeliness Monitoring Project (TMP). As in previous years, CMS will once again be conducting an industry-wide monitoring project in 2021.
Beginning with the 2021 TMP, CMS will no longer collect the Part D Coverage Determination Appeals and Grievances universes used to evaluate these measures. The review time period is starting one month sooner, in January.
Part C sponsors with active contracts in both CY2020 and CY2021. If you had a program audit in 2020, you are off the hook if you successfully submitted the ODAG universes without any Invalid Data Submission (IDS) conditions and had at least one month of 2020 data for each of the required universes. If you did have an IDS on any of the required universe(s), the good news is you only have to resubmit the affected universe(s). If you had just a validation audit in 2020, you are still on the hook.
The CMS Annual Readiness checklist is published right when we are all eyeball deep in AEP readiness. The checklist is intended to be a reminder of common failures guidance that is expected to be implemented by 1/1/2021.
The following is Madena’s approach to using a readiness review to feed into a Compliance Program Effectiveness (CPE) risk assessment and internal monitoring activities.
In August, we recommend plans use the prior year’s CMS Annual Readiness checklist PLUS a readiness checklist that spans other important functions not included in the CMS checklist. Create a true measurement of readiness:
Through this assessment, you may certify a process as “ready” but it may still have inherent risk (new staff, manual processes, lots of hand-offs).
Combining the readiness review with the risk assessment is a great way to feed two birds with one kernel of corn. You should be able to create your internal monitoring plan from your risk assessment.
When the Annual Readiness checklist comes out, be sure to look for changes from one year to the next. Those processes should be your area of focus and validation of readiness. Sound daunting? Not to worry, we’re here to help. Within our end-to-end Medicare Consulting Services we provide all the tools, templates, and expertise you need to help you navigate this process.
And if you were not able to plan ahead, don’t forget that your readiness review is a critical activity to avoid compliance gaps and a potential notice of non-compliance from CMS.
View/download a PDF version of the November newsletter.