Past Performance: There is Still Time to Get it Wrong

Applying for a 2020 Part C, Part D, or Cost plan? CMS will post final past performance methodology soon, most likely early February, but one thing that is final is the past performance review period is down from 14 months to 12. There is reason not to rest easy.

Applicants had complained that 14 months was unfair, stating non-compliance that occurs during January and February of a given year is counted against them in 2 consecutive past performance review cycles, while non-compliance occurring in all other months is counted in only one review cycle. The agency previously believed a full contract year was necessary to capture all relevant aspects of an organization’s performance, but they have determined there is little value on counting a true contract year.

Starting with the 2020 applications, CMS will review the previous 12 months, counting the application deadline month (February) in its entirety; therefore, the review period will be March 1 of previous year to end of February when application is due.

For those applicants who have already counted your points, do not rest on laurels this month or next month. If your organization incurs additional points while you are working so hard on your application (think program audit CMPs and ad-hoc CAPs), it could derail your efforts for another year.