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Establishing and implementing necessary structure and procedures
Medicare Compliance Officer advice and consultation
Coordination and cooperation with in-house counsel
Ongoing consultation on a retainer basis
Updating policies, procedures, and forms to meet changing regulatory requirements
Liaison and routine dealings with CMS
Medicare Compliance and Quality Improvement Committee
Performance oversight and Reporting-Legal Issues
Fraud, Waste, and Abuse Policies and Procedures and Control Programs
CMS Monitoring and Reporting Issues
State/Federal Regulatory Issues
CMS Monitoring and Reporting Issues
Regulatory compliance and proper reporting, while always critical, is particularly sensitive during the current phase of initiating the Medicare Advantage program by private insurers. CMS has stated that it will require "report cards" on Part C and Part D to determine performance and quality measures for the licensed providers. These reports will be utilized to establish benchmarks for performance, and to highlight providers deemed to be worthy of closer monitoring and oversight.
The firm cautions its clients to be very attentive to the quality and content of these reports, because it believes that CMS is looking for low quality providers either to penalize or limit them, or, in the extreme circumstance, forfeit their certificate to write the business. Given the substantial monetary investment required to enter this market, such a penalty would be devastating and extremely costly.
At the present time, CMS appears to be concentrating on marketing practices, and initial high disenrollment and complaints by consumers. The firm will constantly monitor CMS releases and industry reports to maintain awareness of 'hot spot' or critical regulatory concerns.