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Are you ready for your Medicare Plan Finder CY2021 Quality Assurance Testing?
The data files for Calendar Year 2021 Medicare Plan Finder (MPF) files are currently in preview mode prior to going live in the Medicare Plan Finder on October 1, 2020 for Plan Year 2021 enrollments.
CMS expects Medicare Part D Plan Sponsors to perform Quality Assurance Activities prior to submitting MPF files to CMS. A couple of key points:
- Inaccurate data submissions may result in Part D compliance and enforcement actions including suppression.
- MPF submissions must be complete and accurate in all respects, and Part D Plan Sponsors are solely accountable for any errors in their MPF data, regardless of how the data is submitted.
- The MPF is an essential tool for Medicare Beneficiaries to determine which plan they will enroll in based upon the cost of their medication as well as the availability of their pharmacy provider.
- CMS will suppress the display of a Plan Sponsor’s data or plan information as a result of any inaccuracies or if the Plan Sponsor does not respond to a CMS inquiry on the quality or accuracy of the data, resulting in the Plan Sponsor not being able to enroll beneficiaries during the period in which they are suppressed from the on line enrollment center.
There are three distinct monitors that CMS uses to assess the accuracy of the drug pricing displayed by the Plan Sponsor.
- CMS creates a score comparing the prices beneficiaries actually pay for their medications by using the claims data submitted to CMS in the prescription drug event (PDE) files compared to the data that is submitted in the MPF to determine the accuracy of the prices provided in the MPF files. This is reported in a measure called DMD18. CMS pays close attention to cases in which the PDE represents a higher price paid by the beneficiary than was reported in the MPF pricing submitted files. CMS also monitors this from the reverse side as well.
- There is a measure that looks for Plan Sponsors who may artificially inflate their MPF files to have a better score in the first measure. So, this is monitored by a second measure named DMD10 for Plans that submit a higher price for display in the MPF than is actually charged to the beneficiary in the PDE.
- And lastly, there is even another CMS measure that measures the stability of a Part D Plan Sponsor’s point of sale prices to beneficiaries – DMD08. The measure looks at the changes in prices over the contract year. As you can see by the emphasis of three distinct monitors by CMS, the MPF file submission process is very important and highly monitored by CMS.
So now is the perfect time to take a look at your current quality assurance activities and your overall policy and procedures for your Plan’s MPF submission and oversight process to ensure you have the right steps in place to assist with your compliance and oversight efforts.
Stay tuned for an upcoming three-part series on how as a Part D Plan sponsor, you can ensure you have proper Quality Assurance Activities in place for routine oversight and monitoring of the Medicare Plan Finder Pricing files.
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