You Should Know...
New Plan Creation Less Onerous
As we discussed last month, CMS is cracking down on Medicare Advantage Organizations (MAOs) regarding adequacy of provider networks. This in response to multiple beneficiary complaints and failed network audits. The CMS pressure is to take the form of routine electronic submissions of provider network composition by MAOs to CMS. These new regulations were looking to significantly increase compliance costs across the board.
Well, there might be some relief after all.
Documentation of provider adequacy is accomplished through the healthcare service delivery (HSD) table portion of the Medicare Advantage application that’s submitted by MAOs to CMS for both the renewal of and new Medicare Advantage plans. It's easily the most complex portion of the application.
The draft Medicare Advantage new plan application for 2019 has been released and It contains one big surprise—-the removal of the HSD requirements for new plans. Tighter ongoing enforcement will proceed as planned, it’s just that network adequacy won’t be assesses for new plans. Additional, longer-term enforcement was discussed as were heavier sanctions for non-compliant plans.
The upshot—-you won’t have to prove your provider network meets CMS standards with your new plan, but you better make sure they do. If your network is found wanting on subsequent audits, the sanctions are going to be much more severe than currently.
If the draft is approved as written, then it should be much easier and less expensive to get your plan approved. However, if you try to cut corners and your patients complain of their inability to access care, it just might cost you more in the long run.