Health plans that participate in the Medicare Advantage (MA) and Part D programs should already be preparing to adapt to a large number of potential changes to the data and testing protocols the Centers for Medicare and Medicaid Services (CMS) uses during its audit process. CMS released the draft 2017 audit protocols in June 2016 and the comment period for the proposed changes extends until August 12, 2016. The rules may not become final until late in the calendar year, but there are steps plans can take now that will help them prepare for the 2017 audit season.
As proposed, the changes include two major categories: data structure across all audit protocols and testing procedures. Changes include but are not limited to:
Each of these changes has its roots in a push to improve the efficiency and accuracy of the audit process. For plans, however, the immediate question isn’t as much “why” as “what” – less the nature of the changes, and more the number of them.
The new audit protocol details are likely to require plans to make internal changes to their compliance standards. Their data structures and monitoring programs may need to adapt in ways that are as numerous as the protocol updates themselves, even if each change appears minor. Many of the necessary adaptations are unlikely to change between now and when the protocols become final.
What can plans do now? They can make sure all internal players are meeting and planning cross-functionally so their organizations bring a unified effort to the change. They can also start programming in the testing environment, pulling data into the proposed new layouts, and conducting mock audits of their own. Deloitte Advisory will continue to monitor for the final protocol changes, and is ready to support plans in their ramp-up efforts.
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