Uncategorized Archives • Tier 1 Pharmacy Consulting

2020 Readiness Checklist for Medicare Advantage Organizations & Prescription Drug Plans

November 27, 2019

Last month, HPMS released a memo outlining its 2020 Readiness Checklist for Medicare Advantage Organizations and prescription drug plans.

The Centers for Medicare and Medicaid Services recommends all Medicare Advantage and prescription drug plans review the checklist – and take the appropriate action to meet the requirements next year. Health plans should closely review the entire checklist to ensure compliance. Remember, the checklist isn’t a compilation of suggestions from the government. Instead, it’s a summary of the most critical requirements.

Here’s a few examples of what’s in the readiness checklist for 2020:

Medicare Plan Finder Data. Part D Sponsors must provide access to the Health Plan Management System Part D Pricing File Submission Module.

Prescription Drug Event Requirements. Part D Sponsors must submit the data CMS needs to carry out payment provisions through the Prescription Drug Front-End System and processed by the Drug Data Processing System.

Coverage Gap Discount Program. The agency is asking Part D Sponsors to understand their responsibilities to participate in the CGDP, and provides information about the CGDP portal, onboarding training and more.

Precluded Providers and Prescribers. CMS has bigger expectations for 2020 when it comes to managing precluded providers and prescribers. Moving forward, MAOs/Part D Sponsors must, when when a prescriber is on the Preclusion List, deny payments for reject a pharmacy claim, deny a beneficiary request for reimbursement, or deny a health care service.

What Can Your Health Plan Do Next Year?

Tier 1 Pharmacy Consuting can make a readiness assessment for your health plan or prescription drug plan to ensure you are prepared and identify potential problems before they begin.

Get Started

Tier 1 Pharmacy Consulting can work with your staff so everyone understands his or her responsibilities and how to successfully tackle them. We can help you develop a Star Ratings plan for 2021 that will help your health plan improve its performance and achieve your goals.

Tier 1 also will help you sort out conflicting messaging, outdated information, missing information, records and measures evaluated by CMS for its Star Ratings program. With us, you can rest assured that making changes doesn’t have to be complicated or overwhelming. It’s important that you earn the highest rating possible.

A four or five star rating is within your reach for 2021. We can help you get there.

About Tier 1

Tier 1 Pharmacy Consulting is a Denver, Colorado-based pharmacy benefit consulting firm offering customized services to healthcare plans that offer prescription drug benefits. Whether your health plan is big or small, Tier 1 offers strategic, cost-saving solutions that boost the plan’s overall value and help its members by providing high quality care.

Tier 1’s founder is a clinical pharmacist with more than a decade of experience in pharmacy benefit management. We are passionate about collaborating and developing effective strategies to improve health plan outcomes.

Tier 1 offers health plans a new perspective on how to manage their pharmacy benefit. Our team is made up of experts who strive to make effective plans even stronger and fill in any gaps due to a lack of time or resources.

We’re here for you. Drop us a note at info@tieronepc.com and let’s get connected.

It’s Time to Make your 2021 CMS Star Ratings Better Than Ever

September 22, 2019September 23, 2019

The Centers for Medicare and Medicaid Services plans to release its 2020 Star Ratings in October. Whether you received four or five stars or lower, the clock is ticking if you want to have a positive impact on your health plan’s rating next year.

It takes time to ensure your health plan is doing everything it can to ensure a four or five star rating. It’s a challenging task, but it’s feasible. An experienced Medicare plan consultant like the team at Tier 1 Pharmacy Consulting can help you prepare for rating season – and ensure the best outcome possible.

What are Star Ratings?

Most Medicare Part D and Medicare Advantage plans understand the importance of Star Ratings. The ratings are put out annually by the Centers for Medicare and Medicaid Services to give beneficiaries a look at the quality of the health plan before they sign up. Star Ratings focus on aspects of high-quality care within the control of the plan. They provide a complete, accurate, reliable, and valid picture of a program. Star Ratings also are used for compliance and monitoring, and measure aspects of a plan that are relevant and important to beneficiaries. CMS looks to NCQA, PQA and others for measure concept development, endorsement, and specifications.

Star Ratings are displayed on the Medicare Plan Finder – which recently got a huge facelift – so seniors may consider both quality and cost in their enrollment decisions. In other words, Star Ratings are very important.

Here are a few tips going into 2021.

If it’s broken, fix it – with help. If your health plan has been using the same tactics year after year and not seeing a ratings increase, it’s time to change your strategy. Look at your data, measure it, and seek an outside consultant to give you an objective picture as well as an action plan moving forward.

Capture the right data. Many plans fail to earn four stars because they don’t capture HEDIS, PDE, and other important information. It takes time, and health plans have enough going on during a busy fourth quarter. Hire someone to look at issues and resolve them for you – before it’s too late.

Invest in CAHPS. CAHPS are weighed more heavily now, making up a huge portion of the overall Star Rating. Make sure your CAHPS performance is as strong as your HEDIS investment. If you need, look for someone who can help make sure your CAHPS performance is solid.

Find a Star Ratings expert. As we mentioned in the three previous tips, there’s a lot of work to be done and a lot at stake. Why risk earning a low Star Rating due to lack of time, expertise, oversight, experience, or knowledge? The right consultant can make the difference between one and three stars and beyond.

The Time is Now

If you didn’t achieve four stars this year, you have time to improve and influence your 2021 ratings with the right strategy, data, and attention to detail. It’s important that you review your current performance figures and use the right resources moving forward.

If you earned four stars this year – congratulations! However, now is not the time to sit back and relax. Star Ratings is a competitive process, and the health plans who get top billing have already started taking steps to ensure the same if not better performance next year.

Get Started

A four or five star rating is within your reach for 2021. We can help you get there.

About Tier 1

We’re here for you. Drop us a note at info@tieronepc.com and let’s get connected.

HHS proposes removing safe harbor for drug rebates

April 16, 2019April 16, 2019

Prescription drug prices have risen every year for nearly a decade at rates that are higher than the U.S. inflation rate.

The costs of brand name oral drugs nearly doubled between 2008 and 2016, according to an ABC news report earlier this year. The increase was five times that of the inflation rate.

Generic oral medications saw a smaller increase – yet it was still double the rate of inflation. Specialty medications rose 13 times faster than inflation during the same period.

OIG Proposal

A few weeks after this and similar news stories broke, the U.S. Department of Health and Human Services issued a proposal to remove drug rebates for PBMs. Under the umbrella of the federal Anti-Kickback statute, the HHS Office of Inspector General said the move could ban rebates on brand-name prescriptions, which benefit drug sellers, and protect discounts and services that benefit patients.

The proposed change “may curb list price increases, reduce financial burdens on beneficiaries, lower or increase federal expenditures, remove transparency and reduce the likelihood that rebates would serve to inappropriately induce business payable by Medicare Part D and Medicaid MCOs (managed care organizations),” the OIG’s office wrote.

At the same time, the government is also proposing a new safe harbor to protect point-of-sale discounts that drug manufacturers provide directly to patients. HHS also wants s a second new safe harbor to protect certain administrative fees paid by manufacturers to pharmacy benefit managers.

The proposals are in direct response to skyrocketing drug costs. Proponents worry that some patients are not receiving life-saving drugs because they can’t afford them. Pharmacy benefit managers help health plans manage costs and drug utilization. They do that by negotiating with manufacturers and pharmacies to facilitate beneficiary access to appropriate medications, while managing the costs to the plan.

Even so, according to HHS data, the changes could lower beneficiary out-of-pocket costs. Varying from patient to patient, the proposals if implemented could result in higher premiums. That’s something to keep in mind.

Background

The Anti-Kickback Statute is part of the Social Security Act of 1972. Amended five years later, it made it a crime to receive money or rewards for services offered by Medicare or another federal healthcare program.

Meanwhile, the Ant-Kickback “Safe Harbors” statute of 1987 exempts certain transactions from penalties. They include bona fide employment relationship, personal service arrangements, lease or rental of office space or equipment, referral services and a few more.

HHS makes clear it does not intend to remove protection from rebates required by law, such as rebates under the Medicaid drug rebate program. HHS also intends for protection to continue for drug discounts offered to entities such as wholesalers, hospitals, physicians, pharmacies, and third-party payors in other federal health care programs.

The agency is soliciting comments on whether the proposed amendments to the safe harbor regulation would exclude from protection any price reductions “not contemplated by the proposed amendment.”

The effective date of the proposed update to the safe harbor regulation would be Jan. 1 of next year.

About Tier 1

Drop us a note at info@tieronepc.com. Let’s get connected.

CMS proposes updates to audit Civil Monetary Penalties

March 28, 2019March 29, 2019

Medicare plans and pharmacy teams are being heavily scrutinized by the Centers for Medicare and Medicaid Services – now more than ever before. The changes CMS has implemented for 2019 as well as upcoming proposed changes for the next few years suggest that plans are more likely to be audited than not.

An audit is certainly a black mark on a health plan. It’s stressful. And, it can be expensive.

CMS audit penalties have cost health plans as much as $375,000. In mid-March, the agency released a proposal updating its civil monetary penalty listings for last year’s audits – and the fines are all higher per enrollee. An overview:

Per Enrollee Penalty Amounts in 2017 and 2018

– Standard Penalty: $200

– Aggravating Factors: $100

– Untimely/Inaccurate Beneficiary Communications Standard Penalty: $25

– Untimely/Inaccurate Beneficiary Communications Aggravating Factor: $15

Penalty Amounts for 2019-2021

– Standard Penalty: $212

– Aggravating Factors: $106

– Untimely/Inaccurate Beneficiary Communications Standard Penalty: $27

– Untimely/Inaccurate Beneficiary Communications Aggravating Factor: $16

Why is CMS raising the fines? That remains to be seen. Among other things, officials take into account inflation and cost-of-living adjustments.

CMS plans to release a final plan in April.

Audits are usually conducted once every between three to five years. There are different types, including CMS program audits, PDE audits, one-third Financial audits, BID audits, Formulary Administration audits, Transition Monitoring Program Analysis, Coverage determination/redetermination Timeliness audits and Data Validation audits.

It’s important to be ready at all times for an audit – especially if your health plan has performance issues or has faced CMS oversight in the past.

Plans that do not have a vigorous auditing and monitoring program are at risk of non-compliance with CMS regulations – and resulting fines. Being prepared will help plans identify and respond to potential gaps and address them as quickly as possible. The audit process is extensive, and tough to do when you’re trying to run your plan every day. And, don’t forget, plans only have three weeks from the time they receive an audit notice to be ready for it to get underway. You’re going to need help – and that’s where we come in.

The team at Tier 1 Pharmacy Consulting provides support and consultation for all types of audits. We can review data to ensure accuracy with file layout requirements, interpret data to identify potential issues, craft responses and create corrective action plans. With experience in more than a dozen audits and a handful of mock audits, Tier 1 can find solutions to ensure compliancy and get you through the process.

Get in touch today – before an audit notice lands on your doorstep and costs your plan hundreds of thousands of dollars or more.

About Tier 1

Drop us a note at info@tieronepc.com. Let’s get connected.

CMS Draft Call Letter Released; Opioid Use Worrisome

March 25, 2019

Opioids remain a concern for officials at the Centers for Medicare and Medicaid Services (CMS). The agency has announced that addressing the epidemic – addiction, misuse, overdose and death – is one of its top priorities, and that officials have made big changes to 2019 Medicare Part D Opioid Prescribing Policies as a result.

More recently, CMS included in its Medicare Advantage (MA) and Part D draft call letter for 2020 a proposal to implement provisions of the federal SUPPORT for Patients and Communities Act that that require coverage of opioid addiction treatment programs, including medication-assisted treatment. The letter also encourages health plans to lower the out-of-pocket cost of Naloxone, which can quickly treat a narcotic overdose in an emergency, and, just as importantly, encourage doctors to prescribe the drug alongside opioids just in case. Alternative therapies also are encouraged. CMS says it plans to increase surveillance of opioid misuse with its overuse and misuse monitoring system.

The final version of the call letter will be released in early April. The initial draft also includes:

Changes to Supplemental Benefits

CMS is proposing that Medicare Advantage plans offer supplemental benefits outside the primary health plan to patients that suffer from a chronic illness. Those benefits would include things like transportation to and from medical appointments and other help.

Changes to Star Ratings

CMS wants opioid and benzodiazepine misuse measures included in the star ratings for MA plans. The idea is to track use and prevent prescriptions being handed over from several providers to patients who have developed an addition – or at the very least are misusing the drug.

Generic and Brand Formulary Tiers

CMS is looking at provisions that would prevent Part D plan formulary tiers from including both generic and brand formularies. Instead, generics and brands would be kept separate.

CMS changes can be difficult to navigate and keep track of. Need help? That’s why we’re here. The team at Tier 1 Pharmacy Consulting are pharmacy benefit plan experts, providing support and consultation for all types of CMS changes. Remember, plans that fail to abide will be subject to a CMS audit. Agency officials are watching health plans very closely this year.

Tier 1 can review changes to ensure accuracy and compliance. In the event of an audit, we will interpret data to identify potential issues, craft responses and create corrective action plans.

About Tier 1

Drop us a note at info@tieronepc.com. Let’s get connected.

CMS FAQ’s to Audit Program: What You Should Know

March 11, 2019March 11, 2019

The Centers for Medicare and Medicaid Services receives hundreds, if not thousands, of emails from health plans with questions about changes and updates to the agency’s audit program. In many cases, CMS says, the same answers are sought. Because of that, the agency has published an outline of the questions organizations tend to ask most frequently.

A little background: CMS releases changes and updates to its Program Audit Process every year so health plans know what to expect in the event they are audited. Such probes include CMS program audits, PDE audits, one-third Financial audits, BID audits, Formulary Administration audits, Transition Monitoring Program Analysis, Coverage determination/redetermination Timeliness audits and Data Validation audits.

Medicare plans and pharmacy teams are increasingly subject to closer CMS monitoring and review, so an audit is more likely now than ever before. Typically, CMS audits plans once per audit cycle, which runs between three to five years. Even so, it’s important to be ready for an audit – especially if your health plan has performance issues.

Audit notifications for 2019 will be sent out starting this month. If you receive a notification, give us a call. The team at Tier 1 Pharmacy Consulting provides support and consultation for all types of audits. We can review data to ensure accuracy with file layout requirements, interpret data to identify potential issues, craft responses and create corrective action plans. With experience in more than a dozen audits and a handful of mock audits, Tier 1 can find solutions to ensure compliancy and get you through the process.

Back to the FAQ. Below, we highlight a few things health plans are most concerned about. The entire CMS article can be found here: https://go.cms.gov/2J7kR4b

Universe Submissions

CMS has tips for preparing universe submissions in the hopes of making the process a little smoother on both sides. For example, the agency suggests that plans direct any universe questions that arise to the area Team Lead before submission. Plans also should answer “not applicpable” answers as “NA” not “N/A” as seen on many question and answer forms.

Compliance Program Effectiveness (CPE)

CMS has started collecting Call Logs, which help identify misclassification of coverage requests during the Compliance Program Effectiveness portion of an audit. The agency plans to use other ways to look at requests that are filed incorrectly, such as reviewing how well a plan oversees the call-routing process.

Health plans should expect to be evaluated. However, collection of call log data is suspended for 2019. Health plans should still add call log auditing and monitoring activities to their to-do lists and have a documented oversight process in place.

Part D Formulary and Benefit Administration (FA)

CMS says the Medicare Beneficiary Identifier (MBI) or Health Insurance Claim Number (HICN) can be populated for FA record layouts currently requiring submission of an HICN. CMS also indicated that New Member Layout should be populated to include only enrollees for which the plan does not utilize prior claims history.

Have questions for CMS? Email the Parts C and D mailbox at part_c_part_d_audit@cms.hhs.gov or the Medicare-Medicaid Coordination Office at mmcocapsmodel@cms.hhs.gov.

About Tier 1

Drop us a note at info@tieronepc.com. Let’s get connected.

CMS Changes to 2019 Audit Protocol: What You Need to Know

January 19, 2019January 21, 2019

Pharmacy teams can now expect their drug management programs to fall under considerable audit scrutiny by the Centers for Medicare and Medicaid Services regarding a new federal law that aims to prevent prescription opioid misuse and addiction.

For the first time, CMS will look at health plans’ implementation of the Comprehensive Addiction and Recovery Act throughout the program audit process.

The agency released the change as part of its 2019 audit protocols.

CMS releases changes and updates to its program audit process every year so health plans know what to expect in the event they are audited. Such probes include CMS program audits, PDE audits, one-third Financial audits, BID audits, Formulary Administration audits, Transition Monitoring Program Analysis, Coverage determination/redetermination Timeliness audits and Data Validation audits.

Medicare plans are increasingly subject to closer CMS monitoring and review. An audit is more likely now than ever before.

Be Prepared

The team at Tier 1 Pharmacy Consulting provides support and consultation for all types of audits. We can review data to ensure accuracy with file layout requirements, interpret data to identify potential issues, craft responses, create corrective action plans and more. With experience in more than a dozen audits and a handful of mock audits, Tier 1 can find solutions and help you through the process from start to finish.

The next audit notifications will be sent between March and July.

Fewer Deliverables

The CMS changes to audit protocols include some positive news for health plans – including a reduction in audit deliverables. For example, health plans are no longer required to submit Call Logs and answers to supplemental questions during a program audit. CMS has suspended:

The collection of CDAG, ODAG, and SARAG Supplemental Questions at the time an audit engagement letter is drafted. Instead, CMS is encouraging plans to use the questions as a guide to determine non-compliance.
The collection of Call Logs, which help identify misclassification of coverage requests during the Compliance Program Effectiveness portion of an audit. The agency plans to use other ways to look at requests that are filed incorrectly, such as reviewing how well a plan oversees the call-routing process.
The collection of certain CPE data and documentation that can be obtained elsewhere.
The collection of Formulary and Benefit Administration and Special Needs Model Plan of Care enrollment verification evaluation.

CMS also has decided to make three CPE universe data fields optional: CPE FTEAM Column C, FTE Contract Effective Date; and CPE ECT Columns I and J, “Medicare Compliance Department Employee” and “Compliance Department Job Description.” The agency determined each played an insignificant role in determining non-compliance.

CMS also says it will take a broader look into the misclassification of calls as well as compliance and oversight of call routing.

The Bottom Line

Many of the changes for 2019 will reduce the burden on health plans. Others are challenging. Plans should take steps to address the changes and plan for an audit that is likely coming – this year or down the road. We can help.

About Tier 1

Drop us a note at info@tieronepc.com. Let’s get connected.

Medicare Advantage Changes are Coming Next Year. Are You Ready?

January 19, 2019November 28, 2018

Medicare is making a big change to its enrollment period that could benefit new and existing members – but create more work for already-swamped health plans.

Starting next year, Medicare Advantage enrollees will have from Jan. 1 to March 31 to choose the health plan that is right for them, according to the Centers for Medicare and Medicaid Services (CSM). That period had previously ended more than a month earlier, on Feb. 14.

Medicare Advantage members can make changes to their plans during that window, including:

– Switch to a different Medicare Advantage plan that is a better fit for them

– Drop Medicare Advantage in favor of Medicare Part A and Part B

– Enroll in a stand-alone Medicare Part D prescription drug plan (although Medicare Advantage plans already include prescription drug coverage)

– Drop their stand-alone Medicare Part D Prescription Drug Plan

While Medicare Advantage plans offer terrific benefits, including all Part A and Pat B benefits, prescription drug coverage, vision and more, plans can change from year to year. Covered medications, for example, are a common change. That’s why enrollees may consider switching plans.

Health plans should be preparing for the longer enrollment period – and the ability to switch plans – now.

Make sure your data is in order and that the process for members is as seamless as possible. Your website should be updated and easy to navigate so members aren’t confused about their options. And most importantly, your members need to know the change is happening in the first place.

Marketing is key here. It’s important that every new and existing member knows what to do as of Jan. 1 through your website, emails and all other marketing materials. Education is crucial so that members understand what to do and avoid choosing the wrong plan for them.

TV, radio and newspaper ads are also options to ensure the word is out.

It’s going to be a lot of work – complicated work that many plans don’t have the time or expertise to accomplish properly. That’s where Tier 1 Pharmacy Consulting can help.

The Tier 1 team will ensure CMS compliance by developing and reviewing all of the formularies and updating marketing materials. We can also ensure your downstream entities like your PBM are prepared for a longer enrollment period and that monitoring and oversight is in place to ensure compliance with CMS standards. Contact us today.

About Tier 1

We’re here for you. Drop us a note at info@tieronepc.com and let’s get connected.

The Medicare Plan Finder: When Drug Prices are Wrong, Consumers Lose

August 28, 2018

Medicare’s Plan Finder remains the best consumer tool to search for a Medicare Part D and Medicare Advantage Plan. The government wants to keep it that way.

Plan Finder lists all of the health plans available in a person’s zip code and includes crucial information about premiums and out-of-pocket costs, particularly for prescription drugs.

Pricing is different for every health plan, so the tool aims to help consumers to make informed decisions about what kind of health and pharmacy care plan they need – and how much they can afford.

But Plan Finder is only as accurate – or as useful – as the information it receives. Plan Finder drug prices are updated regularly from October through August. Pricing for the current year is frozen in September in preparation for the new plan year’s display.

During the active months, Medicare requires health plans to submit files that update the costs of prescription drugs every two weeks. Many plans delegate this function to their PBM, but it’s important that health plans stay engaged in this process and ensure that there are effective processes to oversight these frequent submissions.

Why? Because Medicare wants to make sure enrollees are provided the most accurate information when making the decision on what prescription drug plan works best for them. .

Let’s say a drug on the Medicare Plan Finder for your health plan is shown to cost $4, but when CMS retrospectively reviews a claim for that drug they see that the member paid$10. This discrepancy can negatively impact your plan performance when it comes to the measure of accuracy of the Plan Finder information, not to mention the potential for member grievances with a cost discrepancy like this.

Here’s what CMS wants plans to do:

Ensure timely and accurate CY 2018 pricing data for posting on Medicare’s Plan Finder.
Identify preferred cost-sharing pharmacy arrangements in the Plan Finder pricing files.
Confirm pricing and pharmacy network data files for the Plan Finder are up-to-date, correct and accurate, and that only pharmacies under contract are included in the tool. Incorrect data may result in suppression from the Plan Finder tool, as well as appropriate compliance actions.
Establish a routine process for sampling a subset of drugs and comparing the pricing on the Plan Finder site versus what is being adjudicated by your PBM at the pharmacy counter.
Evaluate your Plan Finder accuracy ratings report available for your plan to identify any potential areas of improvement.

If a health plan fails to update its prescription drug pricing and other information, it could be suspended or removed from the Medicare Plan Finder. The plan won’t show up when consumers do a search using the tool, so they won’t even know your health plan exists. That means less money going into your health plan and an overall loss of revenue over time.

How we can help

The team at Tier 1 Pharmacy Consulting can be the liaison between the health plan and the pharmacy benefit manager to help oversee the steps needed to ensure CMS compliance, including regular updates to the Medicare Plan Finder. We can offer solutions on how to properly and effectively institute the appropriate process for oversight and ensure drug prices are, at all times, accurate and up-to-date all year.

We are experts in Medicare. Avoid a Plan Finder suppression by partnering with us. We can help you stay compliant at all times, so you can focus on running your health plan.

About Tier 1

We’re here for you. Drop us a note at info@tieronepc.com and let’s get connected.