The South Carolina Hospital Association (SCHA) and members recently met with Region 4 CMS to discuss CMS governance of Medicare Advantage (MA) Plans. This is an issue that has been discussed often in our Physician Advisor (PA) community. Concerns by PAs relate to prolonged observation requirements, delays in payment, volume of denials and incorrect clinical validation audit findings by MA plans. In order to get the issue of MA plan governance elevated, CMS needs to hear from you.
If your hospital is in Region 4 and you are having concerns with the administration of the MA plans related to your work, let CMS know. Do not share any privileged beneficiary information but let CMS know the kinds of issues you are having. This will help CMS understand what and how widespread the problems really are. This will help CMS understand the administrative burden we face dealing with separate rules for each MA plan and the need for more oversight from CMS.
Use the following link to the Region 4 CMS complaint department to make them aware of the degree of issues or concerns you are having with MA plans:
04DMHPOPartDComplaintsRF@cms.hhs.gov
There is also a national website to file complaints and ask for policy revisions. You can go to https://dpap.lmi.org/DPAPMailbox/ and file a complaint or request in the policy mailbox. It is important that as ACPA members and leaders in the PA community that we go beyond discussions within our provider community and take the extra step to comment or make suggestions to CMS on the need to regulate the MA Plans, both contracted and non-contracted.
For example, if we had with one set of rules to follow for visit status determination, i.e. the two-midnight rule, for all Medicare beneficiaries, administrative burden would be greatly reduced. Indeed, one of CMS’ current initiatives is Patients over Paperwork and a promise to reduce administrative burden.
By sending in your concerns and suggestions for policy changes, you can add your voice to CMS in in helping the magnitude of issue that the MA plans disparate rules and seeming lack of consistency with CMS regulations that result in hospitals spending precious Medicare trust fund resources on administration rather than direct Medicare beneficiary care.
R. Phillip Baker, MD
BOD, ACPA