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CMS Overhauls Grievances, Requests, and Appeals Manual Again

After a major rework and massive consolidation of the Parts C & D Enrollee Grievances, Organization/Coverage Determinations, and Appeals Guidance back in 2019, the Centers for Medicare and Medicaid Services (CMS) is back at it with further updates to the all-important manual and guidance to Medicare Advantage (MA) and Part D plans. As many are aware, the manual is the bible for anything related to a grievance, Part C or D coverage request, and Part C or D appeal. Many of the changes come from updated rules as well as the further refinement of the program audit protocols. When CMS discovers something in an audit that raises confusion among plans, they often take the learnings and clarify the manuals further. Plans should be using the manual as a daily operating guide for their departments. From the manual, plans should create their policies as well as standard operating procedures. The manual

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Special Needs Plans Growing As Is CMS’ Regulatory Approach

Note: See my blog for 7/31/2024 to learn more about how dual eligibles receive their care in the Medicare and Medicaid programs. This would be a good primer before you read this blog on Special Needs Plans (SNPs). In January of 2022, Medicare Advantage (MA) Special Needs Plan (SNP) enrollment was just short of 5 million. In July, SNP enrollment (including Medicare-Medicaid Plans (MMP) has grown to 7.15 million, nearly a 44% growth in just 2.5 years. This is about 21% of MA enrollment. The vast majority of the enrollment in SNPs is in the Dual Eligible type (D-SNPs or MMPs), which is about 87% of total SNP enrollment. In both cases, integration of benefits and care between the Medicare and Medicaid programs is the goal. As growth in SNPs occurs, the Centers for Medicare and Medicaid Services (CMS) is upping its audit oversight as well as its strategy toward

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How Do Dual Eligibles Receive Care?

On August 1, 2024, I will have a blog on what is happening with Special Needs Plans (SNPs) and Medicare-Medicaid integration policy. Coincidentally, the Kaiser Family Foundation (KFF) issued a comprehensive analysis on the status of dual eligible healthcare. As such I decided to publish this short bonus blog today as a good primer for some of the issues we will be talking about in the SNP blog tomorrow. The KFF analysis of dual eligible care in Medicare and Medicaid is quite exhaustive. For those not as familiar with KFF, it is the premier healthcare policy think tank in America. I strongly recommend you review the whole briefer. I have posted the briefer link at the end of this blog. I also posted below what I think is one of the most relevant graphics in the briefer as well. I also posted a separate 2023 KFF briefer on characteristics of

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2023 Medicare Advantage and Part D Program Audit Enforcement Report Out. What Does It Tell Us?

Each year, the Centers for Medicare and Medicaid Services (CMS) issues its Part C and Part D Program Audit and Enforcement Report. I liked how CMS did it in years past, where actual plan audit scores as well as average scores by audit area were released. It gave you a great feel for where plans were struggling the most. Nonetheless, the report continues to be a good tool for Medicare Advantage (MA) and Part D plans (MA-PD or standalone PDP) to review and hone their compliance chops. Here are the major findings from this most recent report (link at bottom). As well, I will go through what I heard about 2024 audits from plan friends and contacts. Background CMS has been expanding the audits it does, using both internal and external expertise.  In 2023, a total of 69 MA-PD contracts were audited — 31 of these contracts offered special needs plans (SNPs). CMS also

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Part D Premium Woes Due To The Inflation Reduction Act

Major concerns are emerging that standalone Part D (PDP) plans are seeing skyrocketing premiums due to the unintended consequences of major Part D restructuring and out-of-pocket (OOP) cost reduction passed as part of the Inflation Reduction Act (IRA). A new report by the Council for Affordable Health Coverage (CAHC) asks Congress to intervene on what will be growing impacts in 2025 after premium rises in 2024. The increased costs in Part D are tied to a number of changes in the IRA. I went in-depth on all the Part D changes included in the IRA in an earlier blog on April 15, 2024: https://www.healthcarelabyrinth.com/major-changes-occurring-in-medicare-part-d/ . New costs to plans in Part D due to IRA Here is a brief summary of additional costs in the IRA now borne or will be borne in whole or part by plans since the IRA passed: 2023: 2024: 2025: In addition, PBMs are now

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Will Democrats Be Victim Of An October Surprise Of Their Own Making?

For those involved in politics, candidates and parties fear what is known as the October Surprise, a scandal or national or world event that threatens to upend candidacies and partisan control of federal and state bodies. These events can be planned (e.g., by opponents) or unplanned (e.g., a terrorist attack or other world event). With the election very close, especially with the change at the top of the Democratic ticket due to President Biden’s lagging performance, many are thinking these types of events could be potential game changers on Election Day. But are the Democrats forgetting about a potential October Surprise they themselves may have created that could impact their electoral chances? Let me explain. Medicare enrollment season Each October, the enrollment season begins for Medicare Advantage (MA) and Part D plans. In the MA world enrollment is fully voluntary for individual policies. In the standalone Part D (PDP) world,

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Vertical Integration Appears Very Profitable For Health Insurers And Is Raising Concern Among Lawmakers And Regulators

I have talked often about horizontal and vertical integration in healthcare in these blog pages and on my podcast. One major blog I wrote on vertical integration is here from December 21, 2023: https://www.healthcarelabyrinth.com/do-health-plans-relationships-with-owned-entities-open-up-more-scrutiny/ . Let me recap a little as background before I get to an extremely interesting infographic Jared Strock did recently. Jared is an actuary and health insurer/Medicare Advantage market and finance expert. He posts daily and is well worth following. I posted his graphic, his LinkedIn, and a recent post he did on LinkedIn below. Key background on vertical integration from my earlier blog In comes Strock’s analysis Strock used his financial skills to comb public company financial disclosures to show just how big related-party transactions have become. Here is a summary of what Strock said in his LinkedIn post (link right below the graphic): Graphic source and notes: Q1 2024 financial information for seven major

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Hillbilly Heart: Despite His Conservatism, Could GOP VP Nominee JD Vance Be A Healthcare Maverick?

The political world is abuzz about the naming of Ohio Senator JD Vance as former President Donald Trump’s vice presidential running mate. I will stay out of the broader political fray right now, but I thought it was worth writing about how GOP candidates increasingly do not always meet a strict GOP litmus test on every issue. This could be – I emphasize could – with Vance on healthcare. Vance came to fame with his bestselling book, Hillbilly Elegy: A Memoir of a Family and Culture in Crisis, which recounted the social and economic problems his family faced during his upbringing in Kentucky and later in Ohio. Vance recounts the plight of poor white working-class families in Appalachia, including family struggles with alcoholism and drug dependence, as well as the embedded love of culture and country. He tells of his rise from this meager existence in a one-parent household to

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Medicare Advantage Plans Need To Get Their Focus On Supplemental Benefits Quickly

Medicare Advantage (MA) critics like to shout about revenue overpayments and this is sure to generate headlines and ongoing controversy. But MA plans need to worry about yet another concern from the Centers for Medicare and Medicaid Services (CMS), investigatory agencies, and Capitol Hill. This surrounds supplemental benefits and whether enrollees are benefiting from the vast amount of dollars supposedly earmarked for their utilization each year. This is yet another complicated subject so let’s try to break this down a bit. Rate-setting quick primer As we have discussed on this website often, the rate-setting process in MA has helped MA plans grow considerably. Plans submit annual bids on how much it will cost to deliver traditional Medicare benefits. It then is paid out a portion of the difference between the county benchmark and the bid amount for traditional benefits. This is called the rate rebate. The amount given back to

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Slower Growth From June to July In Medicare Advantage

As noted, I decided to continue my Medicare Advantage (MA) monthly enrollment blogs because of continuing strong month-over-month increases. Admittedly, the continuing growth is tied to remaining strong benefit packages for 2024 and appears to be isolated to a few big plans. Month-over-month growth appears to be slowing a bit, but we are so close to the Fall open enrollment season that I will keep doing these monthly snapshots for those who like to track the data. One new feature in the chart below: you may notice the percentage of MA enrollment against the total Medicare beneficiary population has changed slightly. That is because I stumbled upon a great Centers for Medicare and Medicaid Services (CMS) monthly Medicare enrollment site. It has both annual average enrollment as well as monthly enrollment. This goes all the way to the county level in each state. The site is here: https://data.cms.gov/summary-statistics-on-beneficiary-enrollment/medicare-and-medicaid-reports/medicare-monthly-enrollment . The good

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