CMS released the Medicare Program; Contract Year 2024 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicare Cost Plan Program, Medicare Parts A, B, C, and D Overpayment Provisions of the Affordable Care Act and Programs of All-Inclusive Care for the Elderly; Health Information Technology Standards and Implementation Specifications. See proposed rule changes here.
Medicare Advantage marketing practices remain the subject of heightened scrutiny by CMS. The proposed rule changes will require plans to have an active agent and broker monitoring and oversight plan that monitors and reports noncompliance.
We expect that CMS will make few, if any, changes to the proposed compliance monitoring and oversight for plan year 2024. Medicare Advantage organizations and Part D sponsors should begin creating a robust program for the 2024 annual enrollment period (AEP) that incorporates the following:
· Review of internal grievances
· 1-800- MEDICARE complaints
· Random sampling audits of real-time and past audio sales, marketing and enrollment calls
· Secret shopping in-person education and sales events
· Secret shopping web-based education and sales events
· Targeted and tailored training and retraining programs
· Disciplinary standards and actions
· Internal and external reporting policies and procedures
Once the 2024 changes are final, plans will need to implement an oversight plan that monitors independent, captive or employed agents or brokers in Q4 2023 for AEP 2024.
ATTAC Consulting Group is prepared to help you launch or retool a robust agent and broker compliance program, and to support your auditing, monitoring and investigations resources.