Part D Outcomes Enrollment

Agenda 2017 Pilot Lessons 2018 Cost Change Data Complete Enrollment Contacts Draft Quality Assurance Process Resources

Pilot Lessons 11 states, 2-6 months of participation 45,993 eligible records 70% with complete cost data Multiple fields caused confusion (Drug list ID, password date, notes, before and after costs) Cost changes report between $9,951,414,719 to -$10,911,201,205,031,800

Complete Enrollment Outcome Contact Elements Enrollment Box Enrollment box is checked as a subtopic for either: Medicare Part D, or Medicare Advantage   2. Plan Costs Plan costs in the Special Use Fields (SUF) are numeric, and greater than $0”: Original PDP/MAPD Cost, and New PDP/MA-PD Cost   3. Verifications Verification documentation attached or attest it’s on file: Plan Comparison page from the Medicare Plan Finder (MPF), and Documentation to verify the Enrollment Request. 

Verification Documentation All dollar amounts reported in the performance measures for cost avoidance and savings must have supporting documentation for each individual case. Tried Drug ID List and Password aren’t sufficient and not in new MCT MPF or with Watermark not available in MCT either In OIG reporting, the same dollar amount cannot be counted under more than one measure. Good example of why not including MSP and LIS amounts since counted as part of MIPPA to a great extent. Not many but some concern at duplicate entries of savings information or Part D enrollments vs. comparisons. OIG is looking for the pages that show the original and revised dollar amounts – cite file names and page #s in explanation box. SMPs upload documentation into SIRS, same platform as STARS, and write notes explaining the documents and the dollar amounts. Documents should clearly provide the beneficiary’s name, service date, service(s) provided, and dollar amounts. Written notes of the counselor/volunteer are helpful but not considered sufficient evidence Plan Finder comparison PLUS enrollment confirmation screenshot or scanned images are acceptable and do not provide HIPAA concerns.

Apr – Dec 2018 Cost Change Data Advanced Search for BCF/BAS any entry in SUF1 96,475 any value in SUF Field 1 2,984 removed from list 2,823 $0 only (many API) 161 nonnumeric text 9,490 dollar value >$1 yet enrollment not marked 85,289 total PDP/MA-PD enrollments 6,631 MAPD enrolls 78,658 PDP enrolls 1,288 marked combo of more than one Enrollment  Too early to share results publicly 85,289 Enrollments 6,631 MAPD enrolls 78,658 PDP enrolls 1,288 marked combo of more than one Enrollment

Quality Assurance Needs Nonnumeric value in SUFs Enrollment box selection API mishaps Threshold Duplicate cost change reporting Verification documentation

QA Process Step 1 Cost Change report contains Two cost change reports annually from ACL February report will cover August to January August report will cover February to July Cost Change report contains Contacts for the six month time frame Indicates valid and flagged contacts

Step 2 Timing SHIP reviews, verifies, and edits cost change contacts By Mar. 30: February report covers August to January By Sept. 30: August report covers February to July Confirm 5% of valid contacts have both Plan comparison from MPF with cost amounts Enrollment request in STARS or available in paper or electronic files Review and edit all flagged contacts

Step 2 Valid and Flagged Contacts Valid contacts Enrollment box checked, and SUF cost data is numeric and greater than $0 Flagged contacts Incomplete or missing data, SUF cost data are nonnumeric or $0 Both PDP and MAPD enrollment boxes are selected, or Cost change amounts outside the threshold

Common Enrollment Box Flags Edits Cost data in SUFs, enrollment box not checked. Cost data reported and verification documentation uploaded. Check appropriate MA-PD or PDP enrollment box. Enrollment box not checked, missing verification documents. Enrollment box not checked and required verification documents missing. If verification documentation is available, check enrollment box and upload documents (or attest it is on file). If verification documentation is not available, remove cost data from SUFs. Enrollment boxes checked for PDP and MA-PD. Beneficiary enrolled into one plan yet both the PDP and MA-PD enrollment boxes are selected. Review verification documents and select one appropriate enrollment box. NOTE: During OEP, two enrollments may occur in one counseling session, selecting both enrollment boxes is appropriate in this situation only. No enrollment with SUF Text Issues. No enrollment completed AND non-numeric text entered in SUFs. Remove text data from cost SUFs.

Common Verification Documentation Flags Edits Verification documentation not uploaded API. Documentation not uploaded into STARS due to API or non-Medicare Plan Finder (enrolled by phone, plan website, etc.) SHIP stores verification documentation outside STARS and attest to it. Verification documentation does not exist. Enrollment completed AND both required verification documents do not exist. Remove cost data from SUFs. This applies to API and direct entry states. Verification documentation is incomplete. Enrollment completed, but either the plan comparison or enrollment request form is missing. If available, upload or attest paper or electronic files are available. If unavailable, remove cost data from SUFs (applies to API and direct entry).

Threshold. Record outside the defined cost change threshold. Common SUF Flags Edits Cost data not reported in SUFs. Enrollment box checked AND verification documentation has been uploaded. Enter cost data in SUFs as shown on plan comparison page. Threshold. Record outside the defined cost change threshold. Verify cost data and verification documentation. Enrollment with SUF Text Issues. Enrollment completed, but non-numeric text entered in SUFs. Enter cost data from plan comparison in cost SUFs. Duplication. More than one BCF contains the same Original and New PDP/MA-PD SUF costs. Verify cost data, enrollment, verification documentation and remove cost data for duplicative BCFs.

Records <15k and > -5k Step 2 Threshold Setting thresholds Entry errors: saved $200,742,988 to cost $330,596,694 more Bell curve Ideas? Records <15k and > -5k   BCFs Mean $7,469.69 Standard Deviation $3,150,138.55 1 Std Dev (68.2%) -$3,142,668.86 5 $3,157,608.24 11 2 Std Dev (95.5%) -$6,292,807.41 2 $6,307,746.79 3 Std Dev (99.7%) -$9,442,945.96 1 $9,457,885.34 9 Entry errors: saved $200,742,988 to cost $330,596,694 more Bell curve – might be because we used Original Medicare costs for people without coverage or those changing from some other coverage Other ideas?

Step 3 SHIP Training STARS manual Chapter 4 Beneficiary Contacts pages 20-26 SHIP TA Resource Library www.shiptacenter.org Incorporate Enrollment Outcomes reporting in counselor training Target retraining efforts to flagged list frequent fliers Other needs?

Step 4 Cost Change Attestation Complete the SHIP Part D Enrollment Outcomes Attestation to certify the SHIP QA process is complete By March 30th for February report By September 30th for August report Email the attestation to the SHIP email box SHIP@acl.gov Draft form next slide

Step 5 National Random Sample ACL will randomly sample a minimum of 5% of the Enrollment Outcome contacts ACL will move cost change data for any records deemed incomplete Move cost change data to the notes section b/c don’t want ACL to be deleting data from the system.

Records Retention Grantee record retention policy Retain all documentation for a grant for a minimum of three (3) years after the submission of the final report Current SHIP Grant Example Grant ends 3/31/2020 Final report due on 7/1/2020 Maintain grant documentation to 7/1/2023.

Feedback and Ideas Submit additional comments, concerns, and ideas to the SHIP mailbox SHIP@acl.gov