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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
Prescription Drug Benefit
Plan Services (Part D)
Those companies participating in Part D programs are required to furnish certain reporting to CMS. CMS is taking the initial reports and establishing measures for performance to establish baseline criteria, which will then be used to create future benchmarks. Since these yet-to-be-established benchmarks have not yet been publicized, each Part D provider is faced with the risk that if its performance falls below some unspecified standards, its audit profile will be higher.
The measures currently being utilized by CMS primarily include the following, with numerous subparts beneath each general measure. These measures are available through the CMS website, and are extremely detailed. The firm is available to assist in furnishing and explaining these requirements, with attention to keeping the measures and guidelines thereunder current through the latest updates or amendments of the regulations. One key service offered by the firm, through its CMS Compliance Counsel Department, is to provide notices for updates or revisions to these standards.
The reporting measures are:
- Customer Service
- Complaints
- Exceptions/Appeals
- Data Systems
- Pricing
Following the initial implementation of the benchmarks, CMS will develop future benchmarks. The firm will monitor the published regulations to assure compliance as regulatory requirements change.