Integration of MMP Requirements

MA-PD plans have plenty to worry about with CMS requirements, regulator’s issue of the day, or Central Office determining what issue to hang their hat on today, seemingly changing with the shift of the wind. It is a challenge to keep track of it all, but it’s a necessity we promote and support.

Running like a drippy faucet is the constant stream of sub-regulatory guidance being issued on CMS’ Medicare-Medicaid Integration office web page on the Financial Alignment Initiative. We already know that this population is high-touch, with just about every service requiring preauthorization. Operational areas have to keep up with this guidance and also ensure that they are meeting state and Federal requirements for the care of their membership. Generally, they are getting that guidance from the organization’s regulatory knowledge center: Compliance.

Imagine you are a large, multi-state plan jumping off the springboard into this pool of Medicare-Medicaid Plans, and you need to ensure you are speaking the right language (i.e. Fully Integrated Duals Advantage, One Care, Healthy Connections Prime, Integrated Care Organization, Integrated Care Demonstration Project, and so forth). The fact that the states are on different timelines in terms of implementation doesn’t make it any easier. In this first half of June, for example, the Texas Memorandum of Understanding was posted; one Spanish-language chapter of the Ohio MMP Member Handbook was posted; three separate chapters of the NY MMP Member Handbook were posted, and the reporting requirement templates for Ohio were posted.

I’ve seen plenty of ways that Compliance tracks new rules, memoranda and plan-specific notices, from extremely effective to non-existent. Sometimes the right tool exists but not the right players – sometimes the right staff is in place but with no effective tool. Whatever the state of affairs, this new guidance has to be reviewed, addressed, and if it pertains to reporting or pulling universes, practiced. I can’t stress that enough. CMS gives you the tools and templates; they expect you to be well-versed in how to use them when they come calling.

We are keeping our eyes open in terms of Medicare-Medicaid coordination, in addition to the regularly expected updates from CMS. It should be an interesting next six months as organizations move further ahead in their MMP initiatives, and chances are good that this program won’t look the same a couple years down the road.

This blog was originally posted on blog.gormanhealthgroup.com.

John Gorman: Under John’s leadership, Gorman Health Group has become the leading professional services and solutions firm for government-sponsored health care, providing thought leadership and expert strategic, operational, and technology-based solutions. Read more.