Looking Ahead: Proposed Rule, CBI Conference

CMS-4190-P is scheduled to be published on February 18, 2020. It is published for public inspection now, giving the industry an early start in reviewing and drafting comments prior to the April 6, 2020 submission deadline. There are 895 pages of proposed rulemaking, and although the Centers for Medicare & Medicaid Services (CMS) released a fact sheet about the rule, the summary is just the tip of the iceberg. There are other important aspects of the proposal meriting consideration, not only for operational impact but also beneficiary impact. Think Star Ratings, past performance evaluation, and supplemental benefit eligibility, criteria, and documentation. 

This month I will be speaking with John Wells and Scott Ptacek at the CBI Medicare Pricing and Contracting Congress. This proposed rule could not have come at a better time for presenters. Speakers include representatives of the U.S. Government Accountability Office, Milliman, and NORC at the University of Chicago. If you happen to be in the Alexandria, VA area at the end of the month, this should be an information-packed event, so please join us!

Also approaching is the CMS deadline for Medicare Advantage and Part D new applications and expansions. I wrote about the application process in October. CMS also released their annual calendar of key dates last week. 

For compliance professionals out there, February should be an intense month of reading, partnering with your operational areas, and though it seems unreal, planning for 2021 and 2022. This is especially important for those managing D-SNPs. As always, feel free to contact me to discuss any of these topics.