Author: LBodnarchuk

What Are CMS Documentation Requirements?

Documentation Requirements You Need to Comply with The Centers for Medicare and Medicaid Services

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The Centers for Medicare and Medicaid Services (CMS) require Mandated Documents for Medicare and Medicaid Beneficiaries, which describe member benefits and provide clear and accurate explanations through standardized templates. Since requirements change annually, it’s important for payors to update these documents and relay them to plan beneficiaries to maintain compliance.

Learn more about CMS medical record documentation requirements with ProspHire.

Who Needs the Required CMS Documentation?

Any provider approved to offer Medicare- or Medicaid-sponsored plans to their beneficiaries must comply with CMS Mandated Documents.

If you are approved to offer Medicare Advantage plans, you must follow the directives of Medicare and share up-to-date CMS Mandated Documents with beneficiaries.

What Are the Required Documents for CMS?

While CMS Requirements may vary by plan type, there are generally two categories of required documentation for CMS — communications and marketing. If a document is classified as a communication, it provides information to current or prospective enrollees. Marketing materials might include intent and content intended to draw an enrollee’s attention to particular information.

The two categories of required documentation for CMS are communications and marketing

Plans must submit all marketing documents and some communications to the Health Plan Management System (HPMS) for review. HPMS requires some documents to be submitted by particular dates, while others are considered file and use (F&U), meaning the plan can use the materials five days after submitting them to HPMS for review. If the review finds any discrepancies, the plan may be subject to compliance actions.

These documents include the following:

Annual Notice of Change (ANOC)

Plans must send beneficiaries an ANOC each year, usually in the fall and no later than September 30. This document will detail any changes in cost or coverage that will take effect in January of the following year and is considered F&U.

ANOC and EOC Errata

If there are errors in the ANOC or EOC, plans must provide this document to enrollees immediately after they receive CMS approval.

Comprehensive Medication Review Summary

If enrollees are in a plan’s Medication Therapy Management program, they should receive this document immediately following the comprehensive medication review (CMR) or within 14 days.

Coverage/Organization Determination, Discharge, Appeals and Grievance Notices

If an enrollee has filed an appeal or someone has filed an appeal on their behalf, plans must issue this form based on the relevant time frames.

Enrollment/Election Form/Request

Plans must provide enrollment documents on request, and these materials require an HMPS review.

Enrollment and Disenrollment Notices

Medicare has very specific requirements for enrollment and disenrollment notices. Plans can find specific information on these materials in the Medicare Managed Care Manual.

Evidence of Coverage (EOC)

In the fall, plans must also send an annual EOC document that explains what the plan will cover the following year and how much beneficiaries must pay. This document falls under F&U review requirements.

Excluded Provider Notice

Providers can be subject to penalties for using individuals or entities listed in the Office of the Inspector General’s List of Excluded Individuals/Entities. CMS also keeps a list of excluded entities on the preclusion list. If an enrollee uses a provider listed on one of these excluded provider lists, plans must present them with this notice.

Explanation of Benefits — Part C

When enrollees use a Part C benefit, plans need to provide these materials monthly or per claim with a quarterly summary.

Explanation of Benefits — Part D

When enrollees use their prescription drug benefit, often referred to as Part D, plans must provide this documentation to enrollees by the end of the month following the month when they used their benefits.

Formulary

Also known as a drug list, this communication lists the prescription drugs a plan covers. Plans must make these documents available to enrollees annually by October 15.

Low Income Subsidy (LIS) Notice

If potential enrollees are eligible for Extra Help, plans must provide this document before the enrollment effective date.

Low Income Subsidy (LIS) Rider

Plans must provide this document to current Extra Help enrollees each year by September 30.

Membership ID Cards

Plans must provide both hard and digital copies of ID cards to their enrollees within either 10 calendar days of enrollment or before the end of the month before their enrollment.

Mid-Year Change Notification to Enrollees

If there is a change to the plan rules, benefits or formulary, plans must provide notice of these changes 30 days in advance, unless otherwise stated by the specific CMS regulations.

Non-Renewal Notices

If enrollees are impacted by a non-renewal or service area reduction, plans must provide this notice 60-90 days before the end of the contract year, depending on the material.

Outbound Enrollment Verification

If the enrollee is using an agent or broker enrollment, plans must provide this outbound enrollment verification by hard copy, telephone or email within 15 calendar days of the enrollment request.

Part D Transition Letter

If a beneficiary receives a transition fill for a non-formulary prescription drug, plans must send this letter within three days of adjudication.

Pharmacy Directory

All plan enrollees must receive this pharmacy directory by October 15 for the following plan year.

Plan Termination Notices

Before reaching the plan termination effective date, plans must provide this notice by hard copy and newspaper publication.

Pre-Enrollment Checklist

Plans should provide this document alongside the Summary of Benefits (SB) before enrollment, in the same format the SB is delivered.

Prescription Transfer Letter

If an enrollee’s Part D sponsor requests to fill a prescription at an alternate pharmacy than the one they currently use, plans must send this letter in a timely manner.

Provider Directory

All plan enrollees will receive a provider directory annually by October 15 for current enrollees, within 10 days of enrollment for new enrollees and within three days for current enrollees when requested.

Provider Termination Letter to Beneficiaries

If an enrollee’s provider is no longer part of the plan’s network, plans need to notify enrollees by hard copy via mail 30 days before the effective date.

Safe Disposal Information

At a minimum of once annually, plans need to distribute information on the safe disposal of prescription drugs that constitute controlled substances, including information on drug takeback sites in the enrollee’s community.

Scope of Appointment (SOA)

The SOA form provides enrollees with the opportunity to mark which products they want to discuss, and plans must provide this via signed hard or electronic copy or telephonic recording before the appointment.

Star Ratings Document

The Star Ratings document is generated from HPMS following a standard format. Plans must provide one to enrollees before enrollment and upload the document for HPMS review within 21 days of the updated information.

Summary of Benefits

Plans must provide the SB to all enrollees annually by October 15 and submit the document for HPMS review by that date.

Disclaimers

Plans must also include any relevant disclaimers in all CMS required documents for patients.

Contact us to learn how ProspHire can help optimize your required documentation processes

ProspHire Can Help With CMS Compliance

Complying with CMS document requirements often requires annual updates with the participation of various departments, which can impact an organization’s efficiency and optimization. However, failing to meet the document requirements for government programs like Medicare and Medicaid can lead to non-compliance actions like fines and member abrasion.

ProspHire can help organizations maintain compliance and streamline their required documentation delivery management systems. With resources like a Required Documents Playbook and Program Toolkit, ProspHire can help organizations create a foundational operating model to ensure plan beneficiaries receive the necessary documentation on time.

Contact us through the form below to learn how we can help optimize your required documentation processes.

Understanding Medicare Advantage Utilization Management Requirements

On December 14th, 2022, the Centers for Medicare & Medicaid Services (CMS) released proposed revised regulations governing Medicare Advantage (MA or Part C), the Medicare Prescription Drug Benefit (Part D), Medicare cost plans and Programs of All-Inclusive Care for the Elderly (PACE). The proposal’s focus is to increase transparency, improve health equity, reduce the cost of care and improve access to behavioral health services.

Key Medicare Advantage and Part D stakeholders will be able to provide feedback and analysis to CMS regarding the impact of these proposed changes by February 13, 2023. The proposed revisions would begin to take effect, offering guidance for the Medicare Advantage (MA) program contract year 2024.

Prior authorization can be used in a manner that results in potentially delayed patient care, burdens healthcare providers and adds unnecessary costs to the healthcare system. In summary, will focus primarily on the impact the proposed revised regulations have on utilization management and prior authorization. The effort to streamline the prior authorization process and promote healthcare is to improve the care experience across providers, patients, and caregivers.  


The goal of the changes is that enrollees will receive the same access to medically necessary care they would receive in Traditional Medicare.

Key Points

Key points to the 2023 Medicare advantage proposed rule

What does this mean for MA plans? 

For some plans, this legislative change means it is time to re-evaluate current policies and procedures in utilization management and ensure that current practices are consistent with the proposed rule. It is the time to review all existing policies and procedures related to prior authorizations, re-examine workflows and determine if staff have access and are using current traditional Medicare coverage determination materials. It is also time to establish if all coverage determination materials developed by the plan meet the requirements for development and communication. Consideration should also be given to the membership of the utilization review committee and determining if additional members are needed to cover the full scope of the specialties required to provide utilization review oversight. 

How can ProspHire help

We know that a well-functioning utilization management process can improve costs, patient and provider satisfaction and compliance with regulatory requirements. With our experience in utilization review processes, policies, procedures and medical review, ProspHire can provide a baseline assessment, change management roadmap and assist with increasing efficiency, effectiveness and compliance in your utilization management functions.  ProspHire focuses on best practices learned with plans across the country.

To connect with one of our experts, please fill out and submit the Contact Us Form.

ProspHire Names First Chief Marketing & Communications Officer

PITTSBURGH, PA – Founding Principals Lauren and Chris Miladinovich today announced that ProspHire has named Tricia Egry as its first Chief Marketing & Communications Officer. Tricia was previously Senior Director and remains a member of the Firm’s Executive Leadership Team. She is responsible for enhancing and amplifying the ProspHire brand and building and driving a marketing & communications strategy and digital-first programs that drive engagement and conversation, while inspiring a team of nearly 100 employees and consultants across the U.S. ProspHire is a woman-owned and rapidly expanding Pittsburgh-headquartered management consulting firm focused on healthcare advisory, project delivery and strategic resourcing. 

“Since Tricia joined ProspHire in 2021 she has championed an aggressive multi-functional digital marketing strategy that focuses on creating a Best-in-Class client experience to drive lead generation, cross-selling and sales,” said Lauren Miladinovich, ProspHire’s Managing Principal and CEO. “Tricia’s dedication to ProspHire and its people is exceptional and we are thrilled to promote her to be our first Chief Marketing & Communications Officer.”

A proven marketing leader, Tricia brings considerable experience in delivering high-impact, integrated marketing, brand and communications strategies across diverse industries, locations and geographies. Prior to joining ProspHire, she served as National Marketing & Communications Leader of Field Teams at BDO, USA, where she led marketing & communications strategies for more than 60 U.S. offices by managing the development and execution of go-to-market plans that included digital and social media campaigns, public relations and advertising initiatives, sales enablement and bid management and event and sponsorship strategies. She came to BDO through the expansion of Alpern Rosenthal, where she led strategic marketing initiatives for numerous industries as Director of Marketing. Tricia’s career experience also includes being a journalist and news producer for NBC and a disc jockey at several radio stations in Western PA.

“The story of ProspHire is one that I can really relate to,” commented Egry. “It’s a brand that lives at the intersection of relationships and innovation and the leadership aims to help our people, our clients and our communities prosper. I look forward to continuing to evolve the Firm’s marketing and communications program and playing a critical role in our continued momentum and expansion.”

“This is a big moment for ProspHire,” said Christopher Miladinovich, ProspHire’s Principal and Chief Operating Officer. “Tricia’s extensive experience leading marketing organizations at various stages of growth will help our Firm drive revenue and accelerate as we embark on our next chapter.”

What Is Value-Based Healthcare? 

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Traditional fee-for-service healthcare does not always provide a desirable system for all patients. It can result in inadequate or overpriced services, making it a less attractive option for many individuals.  

Value-based care (VBC) is changing the landscape by lowering prices and boosting satisfaction for patients, payers and providers as well as aligning incentives and promoting quality care. 

We are exploring the different facets of VBC to help you better understand this care model. Learn what value-based healthcare really means, how it works, and its many benefits.  

What Is Value-Based Care and How Does It Work? 

Value-based healthcare programs are designed to reward providers for delivering the highest quality of care. They involve incentive payments for the efficiency and ultimate effectiveness of the services delivered. These systems work as a form of reimbursement and rival traditional healthcare programs that operate with retrospective payments based on bill charges.  

The U.S. federal government first introduced VBC programs in 2008 to improve healthcare services provided to people with Medicare as part of the Medicare Improvements for Patients and Providers Act (MIPPA). In 2010, the Affordable Care Act (ACA) also further advanced the development of value-based healthcare.  

Today, both federal and commercial payers are leading the way in value-based care initiatives by focusing on common areas of duplication, supporting care pathways and evidence-based medicine goals. Removing unnecessary variation in care delivery means better outcomes and lower costs. 

Examples of Value-Based Healthcare

Examples of Value-Based Healthcare 

Value-based healthcare is available in a variety of options. The following are some of the most popular programs you can choose from: 

Accountable Care Organizations 

Originally intended for Medicare patients, accountable care organizations (ACOs) coordinate various healthcare providers to offer coordinated care for a defined population of patients. Providers in the organization share not only the responsibility for improving care, but also the associated risks and incentives in quality performance metrics and lowering costs. While ACOs must invest in technology, people and processes to improve care, the risk arrangements often allow for returns on the investment. 

Bundled Payment 

A bundled payment, also called an episode-based payment, encompasses a program that allows patients to pay for an entire episode of treatment for medical and surgical care. The bundled payment methodology usually begins during hospitalization or surgical procedures and ends ninety days after the initiation of the bundle. This allows providers to emphasize not only the treatment provided within the hospital but the post-acute services, such as rehabilitation or nursing care afterward. It helps incentivize better care transitions and utilization of high-quality post-acute providers that keep the patient safe and avoid unnecessary readmissions. 

Patient-Centered Medical Homes 

A patient-centered medical home (PCMH) is another value-based healthcare model that is centered on a team-based approach to care, anchored in the primary care setting. Providers are typically reimbursed with additional payments to support a more patient-centric and care management delivery model often including services for physical health, mental health, wellness and around-the-clock availability to meet patient and caregiver needs.    

Hospital Value-Based Purchasing 

CMS has also established metrics for most US hospitals related to penalties and risks for quality and cost of care. The programs require hospitals to improve performance on hospital-acquired conditions, value-based purchasing and readmission reduction. These programs place a significant portion of Medicare revenue at risk for hospitals and allow hospitals to grow and support other providers in value-based arrangements. 

What Does Value-Based Care Mean for Payers and Providers?

Now is the time to consider examining or re-examining these programs and the impact on quality care and lowering costs. Are the current programs effective? Are patient outcomes improving and is the expense of operating in these models truly impacting cost? While research is mixed, there is no question that rethinking healthcare reimbursement is here to stay. The most successful organizations are finding the right combinations of care management, pathways, reimbursement and patient engagement that is pushing healthcare delivery in the right direction. 

There are several challenges to success in value-based care. One challenge is access and analysis of timely data that provides the necessary feedback on what is working and what may not be working in care delivery. Often data that providers see is outdated and not well presented to allow real-time interventions or change. 

Another challenge is the lack of coordination between payers and providers and coordinated use of resources for patient/member care management. Care management services may be offered by physician practices, hospitals and payers without a patient-centric approach which can be duplicative and sometimes conflicting. In an ideal system, these important care management and care transition services should be coordinated and focusing on ensuring patients are guided through chronic and acute illnesses and services without overlap or complications. 

Working together, payers, providers and patients can optimize value-based care models by learning from past experiences and continually finding new and innovative ways to align incentives, improve engagement and concentrate on quality outcomes and appropriate costs. 

ProspHire wants to help you provide the highest quality of care.

Turn to ProspHire to Learn More 

Value-based healthcare can assist in advancing the Quadruple Aim. From providing better care at lower costs to improving health management strategies, this type of care offers many benefits. 

At ProspHire, we want to help you provide the highest quality of care possible for your patients. With our team’s extensive healthcare industry knowledge and commitment to delivering valuable results, we are here to optimize your project resource management. 

Are you interested in learning more about how ProspHire can enhance your organization’s processes and improve your performance with integrated clinical care solutions?Contact us below to get started today! 

Hannah Hess and pup

ProspHire Honors the Memory of Managing Director Hannah Hass

One year after ProspHire Managing Director Hannah Hass passed away, the Firm unveils ‘In Her Shoes’, a Women in Leadership Training Program, in her honor. This program is focused on inspiring and empowering the women of the Firm through professional development.

‘In Her Shoes’ is a 6-week program that aims to develop future female leaders within ProspHire, focusing on driving innovation, creating high-performing teams, managing difficult situations and developing within your leadership style. “In memory of our colleague and dear friend, Hannah Hass, the ‘In Her Shoes’ program is dedicated to making a positive impact on ProspHire’s Women in Leadership by women empowering women,” says Lauren Miladinovich, Co-founder, Managing Partner and CEO of ProspHire.

The oldest of three sisters, Hannah spent her early life exploring the hills and mountain rivers near Elkins, West Virginia. She loved being on the river and you could often find her sharing a kayak with her German Pinscher, Franz. She had a successful career as a consultant at Deloitte and moved on to build a loving work family at ProspHire, where she was admired by her colleagues for her independence, intelligence and humor. Hannah loved bringing people together.

Donations may be made in Hannah’s name to Project HEAL.


Remembering ProspHire Senior Principal Advisor Rick Dorman

It is with great sadness that we inform of the passing of our friend and colleague Rick Dorman. After facing a battle with cancer, he died on November 12, 2022, with his family by his side. Our sincere condolences go out to Rick’s family during this difficult time.

“Rick represented the best qualities of an advisor, partner, mentor and teammate,” said Lauren Miladinovich, Co-founder, Managing Principal and CEO of ProspHire. “He will be greatly missed by his colleagues across the Firm.”

Rick spent 27 years at Deloitte Consulting, becoming Principal in 1999. Upon retiring, he became an advisor at ProspHire. He was passionate about project management and business development. He was candid, but kind – he never held back. He was a man of sarcasm with much love behind it.

He was an active force on the ProspHire board of advisors and coached new and aspiring partners. Those who worked closely with Rick know how much pride he took in his profession and how he enjoyed life enthusiastically. His knowledge of wine often led to him being designated to select the wine for leadership team dinners.

“More than anyone I know, Rick loved life, he loved the profession and he loved ProspHire. He was the consummate teammate and friend and cared deeply for every staff member,” shared Chris Miladinovich, Co-founder, Principal and Chief Operating Officer of ProspHire. “Together, we remember Rick and the indelible legacy he left at the Firm.”

Rick was a mentor to many, including ProspHire’s Dan Crogan, Principal and SVP of Consulting, when he entered the Firm’s partnership. “Rick brought a wealth of business knowledge to the executive leadership team, but more importantly he was a great man and dear friend,” said Dan. “His patience and mentorship behind the scenes will be truly missed.”

Donations may be made in Rick’s memory to the Target Cancer Foundation (www.targetcancerfoundation.org) or the Woodlands (www.mywoodlands.org).