Transitioning toward data-driven payment integrity solutions

Evolving payment models and new technologies are supporting health plans’ efforts to implement more proactive, data-driven payment integrity solutions. We recently sat down with Subrahmanyam Mantha, Vice President, Payment Optimization for Discovery Health Partners, to discuss what’s in store for the future of payment integrity and how Discovery is helping clients make the transition from retrospective to prospective programs.  

You’re the newest member of the Discovery leadership team. Can you share your experience prior to Discovery?

Over the past 20 years, I’ve held several positions in building payment integrity programs and supporting managed care organizations. This combination has given me a unique perspective of the entire claims lifecycle and where and when errors can occur. It also has afforded me insights into industry best practices from helping numerous payment integrity organizations set up audit programs and scale them in both post- and pre-pay.  

What trends have you seen that are re-shaping payment integrity optimization strategies?

During the last decade, a number of emerging trends have impacted health plans’ ability to reduce their exposure and increase payment accuracy. Value-based contracting, for example, has left many payers struggling to figure out how to transition to the performance-based payment methodologies that center on cost efficiency, quality, and delivery standards. The changes around CMS’ reimbursement models for home health and skilled nursing can pose some challenges as provider and payers adapt to those changes and create new PI audit opportunities. Payment integrity programs can provide needed support in adapting to claims processing changes like these.

At the same time, providers themselves are evolving and making changes to their billing processes based on these new models. In order to mitigate potential payment errors, health plans are moving from a retrospective process of identification and recovery to a more cost-effective prospective approach. Through clinical audits focused on the provider type, place of service, and their reimbursement models, plans can verify that services billed were performed, ensure proper payments, and avoid the costs of recovery. Payment integrity has a role to play here. Focused payment integrity programs that take a holistic approach to claims auditing enable health plans to shift from cost recovery to prevention and cost avoidance, thereby increasing claim payment accuracy.

What are some of the ways Discovery is helping clients transform their payment integrity approaches?

As industry needs change, we’ve stepped up our payment integrity capabilities with the addition of new talent, technology platforms, and analytical tools. We continue to expand our core offerings, adding new services and strengthening our cost avoidance competencies to help clients address their payment integrity challenges. Furthermore, Discovery is adding resources through strategic partnerships, and last year we acquired HealthMind, which brought us core payment integrity expertise and an integrated end-to-end-payment integrity application enabled by analytics and workflow that greatly expands our pre-pay solutions portfolio. With this new platform, we are scaling our payment accuracy capabilities and portfolio and building focused solutions around urgent care, home health, skilled nursing facilities, high-cost drugs, and more to help clients shift their focus to cost avoidance while still supporting recovery operations.

How is Discovery using data to evolve its payment integrity approach?

The healthcare industry is accelerating its adoption of cutting-edge technologies like artificial intelligence and machine learning to add efficiency and cut costs across operations, including in the payment integrity space. With the HealthMind acquisition, we’re well-positioned to support data-driven solutions and secondary code edit, provider audit, and data mining capabilities. This expands our ability to leverage analytics, artificial intelligence, and machine learning to audit millions of claims every month and find the “needle in the haystack” claims that yield the highest savings for health plans. We are also using analytics to identify patterns in client data that are specific to that provider. We can use that information to educate clients on how to address specific trends to improve their billing processes. We can also help them identify opportunities to change behaviors, so they are able to pivot to a proactive payment process.

Going into 2020 and beyond, our focus is to build on our technology foundation to provide full end-to-end payment integrity solutions for health plans that don’t have those resources in-house. We will also continue providing support for plans that have an internal payment integrity function.

Health plans are looking for a true partner who can help them support and enhance their payment integrity efforts so they can better control costs associated with incorrect billing and overpaid claims and improve administrative and medical loss ratios. With years of experience supporting both payment integrity and managed care, it is clear that Discovery is that partner. Our connected payment integrity approach—combined with our dedication to partnership, responsiveness, and relationships—delivers results that go far beyond financial value.

Find out how Discovery Health Partners can help strengthen your payment integrity initiatives in 2020. Contact us today!

Subrahmanyam ManthaTransitioning toward data-driven payment integrity solutions
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ESRD: Finding and restoring underpaid CMS premiums in five steps

Medicare Advantage (MA) enrollment is on the rise, helping to boost health plans’ annual profits to $35.7 billion in 2019.1 These enrollment increases are expected to continue in 2020, so it’s critical to make sure CMS properly pays you for all your MA members.

Especially when it comes to members with end-stage renal disease (ESRD), the final stage of chronic kidney disease that requires patients to undergo costly dialysis or kidney transplants. Members with ESRD account for a disproportionate amount of medical expenses. Experience shows that health plans are underpaid an average of $60,000 in CMS premiums for each misidentified or inappropriately documented ESRD member. Without a strategy to identify these members, your MA plan could be missing out on millions of additional premium dollars from CMS.

CMS allows health plans to identify, investigate, and restore up to 84 months of underpaid premiums for members with ESRD. Your plan maintains responsibility for identifying those ESRD members and ensuring data is validated and corrected according to CMS guidelines. It can be a challenge to sift through CMS monthly membership reports (MMRs), plan eligibility files, and claims data to find any potentially underpaid premiums.

However, with a systematic approach, plans can gain control of ESRD member statuses and restore underpaid premiums. Let’s look at five ways you can take control of your ESRD premiums.

#1: Explore the hidden value in your data

Your data is critical to restoring underpaid ESRD premiums. Potential missing flags can be hidden in various, disparate data sources and take years to uncover. You will want to dedicate resources and analytics to bring these data sources together and surface anomalies. By regularly combing through MMR, eligibility, and claims data going as far back as 84 months, you can identify likely ESRD members that require further investigation.

#2: Investigate cases that show opportunity

After using your data to identify possible opportunities for ESRD premium restoration, you will want to investigate each case to determine what funds may be owed to you. With the right investigation process, you can determine the root-cause issues for each ESRD member you identified. Then outline the right process you need to follow to address the issues with the appropriate submitting authorities.

#3: Remediate the case

Once you have properly investigated the possible ESRD case, you will want to use that information in your remediation efforts. Your investigation will have uncovered the root cause of the problem, inaccurate or incomplete submissions, and any inconsistencies in the data. In your remediation efforts, you will use the right method of outreach and coordinate with dialysis centers, CMS, or other third parties to ensure the information is corrected and updates are confirmed.

#4: Restore underpaid premiums

Your investigation and remediation efforts will have given you the information you need to seek premium restoration. At this point, you will have corrected the information and submitted it to CMS for restoration. As soon as that has been done, you will want to diligently track and reconcile restored premiums and monitor future premiums for accuracy for as long as it takes to make sure revenue is fully realized.

#5: Monitor premiums

After you have worked to restore premiums, you will want to continue to ensure that all ESRD members are identified. Whether you review data on a monthly basis or do a health check twice a year, you will want to ensure that identified ESRD member statuses continue to be reported accurately and that correct premiums continue to be paid.

Plans that take a systematic approach to analyzing and reconciling their ESRD membership can successfully restore underpaid premiums and ensure accurate premium payments going forward. Many plans find that partnering with an experienced ESRD premium restoration vendor to focus on the things outside the plan’s control can help maximize results.

 

Contact Discovery Health Partners today to find out how we can help you restore underpaid premiums for members with ESRD.

1Fierce Healthcare, “Health insurers’ profits topped $35B last year. Medicare Advantage is the common thread,” February 24, 2020.
Jeffrey MartinESRD: Finding and restoring underpaid CMS premiums in five steps
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Fixing payment integrity at the source

“New year, new me.” Seems like we hear this at the beginning of every year and hold on to the promise of moving on from the past and setting new goals for the future. Likewise, healthcare organizations are kicking off 2020 by charting new paths to address old problems and expanding into new initiatives to stay ahead of the competition.

Priorities such as increasing member satisfaction, provider relationships, and regulatory compliance remain top of mind for many health plans, which makes it a good time to take a fresh look at your payment integrity strategies and resources. Now is the time to evaluate how well your plan is maximizing recovery opportunities, improving cost avoidance strategies, and exploring premium restoration possibilities. To do this, you need to start at the source of your payment integrity challenges: eligibility data.

The impact of eligibility errors

It’s a known fact that improper payments abound in healthcare, many of which stem from eligibility errors made as a result of multiple data sources, outdated technology, manual processes, and members with other insurance coverage. When eligibility errors occur, they affect many payment integrity areas such as coordination of benefits (COB), subrogation, and Medicare secondary payer (MSP) validation. Failing to address these issues leads to incorrectly paid claims, improper reimbursements, or claims that shouldn’t be paid at all—costing your plan millions.

According to Gartner, billions of dollars are spent every year in improper claims payments across commercial, Medicare, and Medicaid lines of business. Gartner research states, “Payer CIOs must get proactive and leapfrog current performance by focusing on prospective payment integrity capabilities.” With this in mind, what can you do to strengthen your payment integrity approach?1

Identify inaccurate eligibility data

When taking a close look at eligibility data, your plan will want to determine which claims may have been paid incorrectly as a result of inaccuracies. We estimate that 20% of a plan’s membership will have other insurance, and of that 20%, the other insurance will be primary 17.5% of the time. For a 200,000-member plan, this represents nearly $5.4 million in incorrectly paid claims. When statistics like this are uncovered, the plan quickly realizes how important it is to keep its eligibility data in check.

Determine a cost-avoidance strategy

Avoiding improper payments is a core tenet of any payment integrity strategy. Accurate and trusted eligibility data plays a key role. We estimate that the same 200,000-member plan could save over $13.4 million by avoiding incorrect payments. With the right cost avoidance strategies founded on accurate eligibility data, the plan stands to see a significant impact to its bottom line.

Look beyond dollars and cents

When evaluating your payment integrity strategy, you will want to think beyond dollars and cents. Quality eligibility data will have a positive effect on administrative efficiency, member satisfaction, and provider relations.

By avoiding improper payments in the first place, you avoid the need to rebill, saving you and your staff valuable time and energy that might be channeled toward other payment integrity initiatives.

Member satisfaction is a key priority for any health plan. In fact, the member experience drives performance on CAHPS (Consumer Assessment of Healthcare Providers and Systems), which is a key driver of Star ratings. Eligibility data drives a diverse number of systems and processes including registration, enrollment, care provision, wellness, and customer care. All of these areas influence your members’ experiences with your plan.

Lastly, providers depend on prompt, accurate payment. When claims are denied as a result of recurrent eligibility issues, payer-provider relationships already burdened by administrative complexity are further strained. Ensuring accurate eligibility data and determinations not only improves efficiencies, it also helps to accelerate reimbursements, greatly improving relationships and alignment.

Consider a connected payment integrity approach

Given the effect that eligibility data can have on payments, you will want to consider a connected payment integrity approach and address any gaps in your technology. Often, challenges arise from multiple sources of data, conflicting or inaccurate data, data integration challenges, manual workflows, multiple reporting systems, and more. By creating a technology environment that can support connected payment integrity functions (e.g., claims recovery, subrogation, and COB), business managers and IT can come together in their thinking and create a single, trusted source of eligibility data.

 

Contact Discovery Health Partners today to find out how we can support your payment integrity initiatives in 2020 and beyond.

1Gartner, “U.S. Healthcare Payer CIOs Must Adopt Prospective Payment Integrity to Thwart Improper Claims Payment and Fraud,” February 13, 2018.
Jeffrey MartinFixing payment integrity at the source
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Jason Brown on the road ahead for payment integrity

As the industry transitions from volume to value-based healthcare, health plans face increasing pressure to better manage costs and ensure payment integrity. We recently sat down with Jason Brown, CEO of Discovery Health Partners, to get his thoughts on recent trends and how they’re shaping the road ahead in 2020.

Healthcare continues to change and evolve. What do you see as some of the trends setting the stage for optimizing payment integrity?

Health plans face a number of challenges when it comes to ensuring the right care is provided to the right member for the right amount. Complex billing processes, changing regulations, outdated and disparate data systems, and overlapping coverage all contribute to improperly paid claims. Today, nearly a third of claims are paid incorrectly, leading to billions in administrative waste.

In 2020 and beyond, we anticipate health plans will continue to struggle with rising healthcare costs, numerous competing priorities, and a lack of resources. Furthermore, changing regulations and mandates will continue to add layers of administrative and clinical complexity to a system already bogged down in paperwork. While there is no clear path to cost containment, there are ways health plans can work toward transforming their payment integrity approaches. An example is leveraging advanced technologies to move from retrospective payment to prospective payment—by detecting improper claims before they are paid, health plans can keep costs in check, increase member satisfaction, and most importantly, cultivate healthy provider partnerships.

What are some of the ways Discovery is helping health plans address their payment integrity challenges?

This past year has been an exciting time of innovation and growth for Discovery. We have an expanded suite of payment integrity solutions—Coordination of Benefits, Subrogation, Data Mining, Clinical Audits (in areas such as diagnosis-related group (DRG) audits and itemized bill review audits) and Premium Restoration. Our integrated solutions are designed to work together. This connected approach helps optimize claims recoveries and avoid future expenses across the entire claim lifecycle while reducing provider and member abrasion.

What makes Discovery unique is that our solutions start with our clients’ own data and processes. We leverage the latest analytical tools and technology like machine learning to identify patterns that present opportunities for cost recovery and cost savings. By blending artificial intelligence with human expertise, we identify hidden errors and root causes that are often overlooked. We also provide the highest levels of support to our clients, acting as an extension of their teams, to free up their internal resources so they can focus on other business priorities.

Since its inception, Discovery has been proud to provide flexible solutions that help health plans solve their payment integrity challenges. Our newly formed Client Council provides a platform for clients to share industry insights and challenges with their peers and help drive product innovations with Discovery. Going forward, custom-tailored solutions like ours will be key to helping plans manage costs while maintaining the high levels of care that their members expect.

What’s on the horizon for Discovery in 2020?

During the past decade, we’ve demonstrated measurable success by helping our clients improve operational efficiencies, increase claims accuracy and payment, and recover dollars back to their health plans.

From 2020 forward, we will continue to evolve existing solutions and create new forward-thinking approaches to help plans prevent and recover inaccurate payments. By expanding our use of data analytics and data integration and accelerating our investments in research and technology like machine learning and predictive analytics, we will help health plans capitalize on information to coordinate claims correctly. Once individual plans reach the point where they are paying the appropriate amount for the healthcare that’s delivered, they can re-invest in clinical care for their members.

At the same time, we will position clients to transition toward a more proactive approach to cost management. Reimagining the payments process and applying insights further upstream will be key to enabling providers to take advantage of opportunities to proactively change wasteful behaviors.

And of course, we’ll continue to keep our finger on the pulse of the industry. By building partnerships with our clients, industry organizations, agencies and others to learn about best practices and stay on top of the latest trends, we can prepare clients for the challenges ahead.

 

Find out how Discovery Health Partners can help strengthen your payment integrity initiatives in 2020. Contact us today!

Jason BrownJason Brown on the road ahead for payment integrity
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A year in review: top blogs from 2019

The new year is upon us and with it comes a new decade. It has been a decade of transformation for healthcare with regulatory changes, health system consolidation, healthcare consumerism, and new technologies that have forever changed the industry. 2019 has been a time of change and growth for Discovery Health Partners as well. Here are highlights from our most popular blogs of 2019 to remind you what we’ve been up to all year.

3 bad habits that are good for subrogation

In February, we talked about the three “bad habits” that can lead to successful subrogation: be unfair, ignore your members, and be pushy. In any other scenario, these tactics can get you into trouble. But for subrogation, being unfair requires that you not treat all cases equally. Ignoring your members is all about avoiding member abrasion. And being pushy involves aggressively identifying and verifying subrogation cases. Altogether, these tactics help improve the opportunity for quick and fair settlement of subrogation cases.

Why Medicare Advantage plans may be losing money on members with ESRD

In March, we featured a post about the challenges Medicare Advantage plans face with members with end-stage renal disease (ESRD). Though ESRD afflicts fewer than 100,000 people nationwide, the disease requires lifelong care—and a disproportionate percentage of medical expense. The blog discusses the gap in CMS premiums for ESRD members and what Medicare Advantage plans can do to better identify them.

It’s challenging to identify and restore underpaid ESRD premiums. Here’s how to solve that

Another popular blog continued the ESRD discussion, highlighting a systematic approach Medicare Advantage plans can take to restore ESRD premiums. This includes automating the process of sifting through data to identify potentially underpaid premiums and maximizing the 84 months that CMS allows plans to identify, investigate, and restore premiums. The blog identifies five key components of an effective ESRD program: analytics, investigation, remediation, restoration, and monitoring.

Subrogation: 3 ways SaaS can help

In July, we returned to the topic of subrogation with a discussion of how software-as-a-service applications can help. Plans are finding that combining SaaS applications with in-house expertise creates a more effective, data-driven approach for finding and validating subrogation recovery opportunities. Specifically, you can: 1) make in-house recovery more efficient and insightful; 2) gain accessible, easy-to-use, scalable, and secure solutions; and 3) do more at a lower cost.

Stay tuned to our blog for more insights on these topics and to see what 2020 has in store. You can also get the latest industry and Discovery updates by following us on LinkedIn and Twitter. Are you interested in learning how Discovery Health Partners can support your organization? Contact us today!

Discovery Health PartnersA year in review: top blogs from 2019
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It’s challenging to identify and restore underpaid ESRD premiums. Here’s how to solve that.

Why it’s a challenge to identify and restore underpaid ESRD premiums

In her recent blog, Why Medicare Advantage plans may be losing money on members with ESRD, my colleague Lyndsay Deckert addressed the challenges MA plans face with receiving accurate premiums from CMS for members with end-stage renal disease (ESRD). I’ll pick up from Lyndsay’s information and delve more deeply into how Medicare Advantage plans can restore underpaid ESRD premiums.

Health plans miss out on millions in premium revenue that can be traced back to missing or inaccurate CMS data about ESRD statuses for MA members. To address this, many plans have developed processes for identifying and correcting inaccurate data, restoring underpaid premiums, and ensuring they collect the correct premiums going forward for their members with ESRD. However, ESRD premium restoration is a complex process that requires combing through multiple data sources to identify potential premium gaps and working through providers to correct ESRD-related patient information. This process is painstaking and requires tenacity.

ESRD reporting is (mostly) out of your control

The first challenge is sifting through data in CMS Monthly Membership Reports (MMRs), plan eligibility files, and claims data to find any potentially underpaid premiums. The clues may be hidden in various, disparate data sources. To make sense of these clues, it helps to have an automated process to bring all these data sources together and use optimized analytical queries to find anomalies in the data. This is in your control.

What’s not in your control is updating the potential missing flags once you’ve identified them. Plans must work with providers who are often pressed for time and resources and are subject to human error. One simple mistake can prevent CMS from restoring a patient’s ESRD status in the member data. This omission can take years to uncover and can cost the health plan millions in the meantime.

Plans can take control of ESRD restoration with systematic approach and patience

CMS allows health plans to identify, investigate, and restore up to 84 months of underpaid premiums for members with ESRD. However, it’s the plan’s responsibility to identify those ESRD members and to ensure their data is validated and corrected according to CMS guidelines.

Plans that take a systematic approach to analyzing and reconciling their ESRD membership can successfully restore underpaid premiums and ensure accurate premium payments going forward. Many plans find that partnering with an experienced ESRD premium restoration vendor to focus on the things outside the plan’s control can help maximize results.

Here are 5 components of an effective ESRD premium restoration program that plans should look for:

Analytics—Comb through vast amounts of MMR, eligibility, and claims data going as far back as 84 months and identify likely ESRD members that require further investigation

Investigation—Determine the root-cause issues for each ESRD member that’s identified and the right process for addressing the issues with the appropriate submitting authorities

Remediation—Use the right method of outreach and coordinate with dialysis centers, CMS, or other third parties to ensure that information is corrected and updates are confirmed

Restoration—Diligently track and reconcile restored premiums and monitor future premiums for accuracy for as long as it takes to make sure revenue is fully realized

Monitoring—Ensure that each identified ESRD member status continues to be reported accurately and that correct premiums continue to be paid

With a systematic approach, time, and patience, plans can gain control of ESRD member statuses and restore underpaid premiums.

Kevin McDonaldIt’s challenging to identify and restore underpaid ESRD premiums. Here’s how to solve that.
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Infographic: ESRD has a major impact on Medicare Advantage financials

ESRD has a major impact on Medicare Advantage financials

Additional ESRD Premium Restoration resources

For more information, please visit our ESRD Premium Restoration resource page or complete the contact form on the right to speak with a Business Development Associate.

Discovery Health PartnersInfographic: ESRD has a major impact on Medicare Advantage financials
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Why Medicare Advantage plans may be losing money on members with ESRD

MA plans may be operating at a deficit for some members with ESRD diagnoses

Among the Medicare Advantage (MA) population, roughly half of a percent of members have a costly disease known as ESRD, or end-stage renal disease. Though this accounts for just under 100,000 people nationwide, the disease requires expensive, life-long care, which results in a disproportionate percentage of medical expense. For this reason, MA plans must ensure they know who these members are and verify that the premiums they’re receiving from The Centers for Medicare and Medicaid Services (CMS) are correct.

The 21st Century Cures Act (CURES; P.L. 114-255) will allow Medicare-eligible individuals with existing ESRD to enroll in Medicare Part C plans beginning in 2021[i]. With this significant change and as MA plans grow in popularity among older Americans, plans can expect to see an increase in their members with ESRD. To help manage this change, plans must focus on maximizing their financial performance so they can continue to remain competitive and offer enhanced benefits and care for their members.

And when it comes to covering the cost of care for members with ESRD, if CMS isn’t correctly paying these members’ premiums, then plans begin to operate at a deficit for these members. They pay the high cost of care, including ongoing dialysis treatments, but they do not receive the revenue to cover those costs. Over time, this adds up to millions in lost revenue for plans.

Higher CMS premiums should cover higher cost of care

CMS pays MA plans a significantly higher premium for each member with ESRD to help cover the higher costs of their expensive long-term treatment and care. The difference between a base monthly premium for a healthy member and a member with ESRD is roughly $6,000.

Because most members with ESRD are affected by a variety of additional health factors that affect their CMS premiums to the MA plan, the actual monthly loss per member can exceed $7,000. You can see how, when those premiums go unpaid, this adds up quickly for a single member and why, for such a small population, the deficit can grow exponentially across the whole population. Considering nationwide MA membership, this represents as much as $600 million in lost ESRD revenue opportunity industry-wide.

ESRD diagnoses go unnoticed

You may wonder how CMS might be overlooking ESRD statuses. The reasons range from clerical errors to eligibility issues to technology problems. Sometimes it’s just a matter of a delay before CMS begins paying the premiums. In any case, it’s incumbent on the health plan to find these errors and work to correct them so they can recoup underpaid premiums.

Like with premiums for Medicare Secondary Payer (MSP), CMS allows health plans to recover underpaid ESRD premiums 84 months in arrears. All MA plans should examine their populations to identify any missed ESRD statuses and corresponding premium errors. They can work through CMS and providers to identify why the errors happened, correct the problems, and restore underpaid premiums.

Is my plan losing out on ESRD revenue?

Possibly. Unfortunately, ESRD premium gaps are difficult to manage because of the reliance on third-party providers such as dialysis centers.

The bottom line is that ESRD patients may not get flagged in CMS data. And since plans don’t have ready access to the information used in ESRD treatment and reporting, they may not even be aware of a member’s diagnosis until months or years into their treatment, after they have already missed out on millions in premiums.

We work with a number of MA plans to find missing ESRD flags and restore underpaid premiums for those members.  We’ve consistently identified millions of dollars in underpaid premiums for plans with more than 100,000 members. And even though some of these plans already successfully identified missing ESRD flags, we uncovered even more.

Learn more about restoring underpaid premiums for members with ESRD.

[i] https://fas.org/sgp/crs/misc/R45290.pdf

Lyndsay DeckertWhy Medicare Advantage plans may be losing money on members with ESRD
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Webinar: Restoring underpaid CMS premiums for members with ESRD

Restoring underpaid CMS premiums for members with ESRD

What you can expect from this webinar

The process of identifying and restoring underpaid ESRD premiums is time-consuming and complex. This can stand in the way of maximizing the premiums you deserve for your membership with ESRD. View this on-demand webinar to learn:

  • Why CMS premiums for ESRD can go unreported and underpaid
  • The challenges involved in identifying underpaid premiums for MA members with ESRD
  • The challenges involved in restoring premiums
  • Discovery’s solution to help MA plans find and restore additional premiums

Use the quick form on the right to view the webinar on-demand.

Discovery Health PartnersWebinar: Restoring underpaid CMS premiums for members with ESRD
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Four tips for balancing the effects of Medicare Secondary Payer

Medicare Secondary Payer (MSP) is a multi-pronged issue for Medicare Advantage plans. If plans aren’t monitoring the effects of MSP on medical and pharmacy claims as well as premiums from CMS, they could be hurting their bottom line—to the tune of millions of dollars. MSP also introduces compliance responsibilities that plans must regard or else face possible consequences.

This requires a balancing act to ensure primacy information is correct for members with other insurance and to verify that claims are paid and premiums are collected in accordance with the member’s primacy.  Plans should work to identify inaccurate primacy information and build processes that can help correct these errors so they can ensure accurate payments all around.

Let’s look further at each area.

Premium

It’s important to realize that CMS primacy information is not always correct. Medicare Advantage plans should be reviewing CMS information each month to verify primacy to identify underpaid premiums as well as overpaid premiums.

What’s your motivation to verify premium underpayments? Your bottom line! Underpaid premiums often cost health plans more than they realize, and, in fact, Discovery Health Partners has recovered more than $200 million in underpaid premiums for Medicare Advantage plans. When the MA plan moves from secondary payer to primary payer for a member, the plan can recoup underpaid premiums going back 72 months. This adds up quickly!

On the other hand, CMS mandates that plans repay premium overpayments within 60 days. Obviously, this is required to stay in compliance, so plans need to ensure they are checking for CMS overpayments as well.

As plans work to identify and correct primacy errors, we always advise them to do a root-cause analysis to determine why dollars were taken from the plan and identify the entity that “took” the dollars. For example, was it due to a Section 111 reporting issue? You can see this on a quarterly basis if you have constant flip-floppers (members for whom you already corrected primacy but who show up again later as secondary). This could indicate a problem on the commercial side of your own plan.

Once you identify the owner of the problem, you can work with them to make corrections. And you can prioritize the work by which entity or problem affected the most dollars for your plan.

Claims

The financial impact of incorrectly paid claims due to MSP is not as great as the premium impact, but it’s still a worthy effort to verify claims that can return dollars to your plan. As you know, primacy order determines how claims should be paid.

As you update primacy information based on a monthly review of CMS files, it’s important that MSP and claims specialists work closely together. As primacy order changes, claims specialists can make sure claims get adjusted and reviewed. They also should make sure that claims systems are updated in order to pay claims correctly to providers.

You also can recoup overpaid claims (claims that you paid as primary but should have paid as secondary). Usually, you can go back 12 or 18 months to adjust claims and recoup dollars—it depends on contracts with providers or state regulations—which can add up to millions of dollars. It seems that CMS is paying closer attention to how claims are paid and if they follow the order determined by the plan, so if you haven’t focused on this before, now is a good time to change that.

It’s important to look at the full picture across premiums and claims—if you’re getting a reduced premium and paying claims as primary, then it’s a double hit for your plan. If you can correct both, it’s an even bigger improvement to your bottom line.

Pharmacy

Part D plans have an obligation to verify primacy and ensure that member drug benefits are available to them when they need them. Plans that use a pharmacy benefits management firm (PBM) to manage pharmacy claims should be sure to share primacy updates with them and verify that they actually use that information. The PBM should pay claims based on recent verification on the medical side.

It helps to ask PBMs about their processes and how they use the information you give them. Ask them to map out the process so you can see that payments will be correct based on the information you share. Again, CMS is looking at this to ensure pharmacy claims are paid accurately.

Tips and tricks

If you’re uncertain about the performance of your MSP process, keep these tips in mind:

  1. Make it an ongoing process. Member primacy is constantly changing, so you have to keep on top of your monthly reviews.
  2. Check everything. As I said before, CMS may have inaccurate primacy information, so you have to double check that each month. Likewise, make sure your recovered premiums match your expectations each month—if you expect 60 months of premiums back, make sure you get the full 60 months.
  3. Assess. Get to root cause of errors and make sure updates get made.  For example, look for constant flip flops for indications such as Section 111 reporting problems. Also, review TRR 245 and 280s, which notify the plan of a member’s MSP status turning on and off. By reviewing and verifying the daily 245, you can avoid losing dollars instead of recouping after the premium has been reduced.
  4. Validate. Other insurers are your best source of validation information. Consider keeping a database of other insurer phone numbers to make research easier and faster. Use all the information available to you—member surveys, Section 111 responses, CMS reports, etc.

For more on this topic, view our on-demand webinar, Walking the line: balancing claims, premiums, and compliance for MA plans.

 

 

Discovery Health PartnersFour tips for balancing the effects of Medicare Secondary Payer
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