Tues., Feb. 27th, 2018

1PM Eastern

Expert Article by
Michelle D. Rigby on:
Cost of Non-Compliance

Cost of Non-Compliance & Partnering with Your (FDRs) for Your Success

First Tier, Downstream and Related Entities (FDR) Medicare Compliance

While attending the 2nd Annual Medicare Compliance Boot Camp last week, a former CMS auditor spoke on maintaining compliance for marketing materials. Spirited discussion followed over the management and fulfillment of correct Section 1557 taglines, preservation of version control, integrity and avoidance of waste triggered by incorrect information errors, associated with items such as ANOCs, when the cost and postage of a kit can run $10-$20 each!

The Facts are Sobering

CMS audits are on the rise, as are CMPs and sanctions
The average CMP is around $750K
Over 46% of sponsors subject to a 2016 Program Audit received a Civil Money Penalty

Of far greater concern, was the discussion of the risk of reputation loss for reducing a Star, or the revenue loss from all of those members. Should CMS decertify a plan? One plan with 26,000 Medicare members, calculated their revenue loss at $14M.

Many mentioned Aetna being fined $1.5M by New York State for leaking members’ HIV status. Something seemingly innocuous as how letters were folded and inserted a window envelope *1 caused this issue.

*1 https://www.reuters.com/article/us-aetna-new-york-settlement/aetna-is-fined-by-new-york-for-leaking-members-hiv-status-idUSKBN1FC2YT

Some of this points to the importance of choosing the right fulfillment partner. The strategic decision to outsource to a qualified fulfillment process engineer can provide an essential risk management tool.  ABG is backed by experience and has created technology-enabled work flow tools to ensure success.  A business associate at a major US Medicare plan customer of ABG’s once told us that they don’t bother with the headache of the fulfillment…  “We just let ABG handle it.

Planning for 2018 ANOCs and other key compliance projects is already top of mind - Many of us have emerged from the busy season with the thought that “something has to change this year.

Article: Cost of Non-Compliance; and Dan Ablett, ABG’s President, for a live round table webinar discussion on Cost of Non-Compliance & Partnering with Your FDRs for Your Success.

Get Ahead of the Curve:
Dan and Michelle will cover 10 actionable ideas you can take away from the webinar to bring about positive changes to your Medicare compliance and member communications programs ahead of the next coverage year.

Meet The Webinar Presenters

Michelle D. Rigby

Director of Client Services
at BluePeak Advisors

Michelle is the author of The Cost of Non-Compliance. She has 20 years of health care compliance experience at both the health plan and PBM level to include Medicare, Medicaid and
Commercial Products.

Dan Ablett

at ABG Communications

Dan is a Compliance Officer and has supported compliance audits as an FDR for both small and large plans (9+ million lives). At ABG, he promotes the use of: A patented solution that saves over $2M.

Did You Know?

Forty-six percent of sponsors subject to a 2016 Program Audit received a Civil Money Penalty (CMP) for violations of Medicare Parts C and D requirements found by CMS during the audit. Penalty amounts relating to program audits ranged from $28,975 – $2,498,850. What’s more, the total number of sponsors that received a CMP related to program audits increased by 50 percent between 2015 and 2016. CMS also imposed four penalties relating to other program noncompliance issues, ranging from $3,325 – $106,095.

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