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CMS recently released a proposed draft of its Medicare Reporting Requirements document for 2016 and, for the first time, the guidance includes reporting requirements for Medicare rewards and incentive programs. The new reporting requirement is slated to begin January 1. Are you ready?
The Centers for Medicare and Medicaid Services (CMS) recently released a proposed draft of its Medicare reporting requirements document for 2016 and, for the first time, the guidance includes reporting requirements for Medicare rewards and incentive programs (RI programs). The new reporting requirement is slated to begin January 1.
CMS now permits Medicare Advantage organizations (MAOs) to offer one or more rewards and incentive program to currently enrolled members. In fact, innovative MAOs are already developing or implementing Medicare member engagement programs that provide rewards and incentives to members for participating in activities that improve health, prevent injury and illness, and promote efficient use of healthcare resources. Plans have a choice in whether or not they offer rewards and incentive programs, but if they do, they must comply with the regulatory requirements set forth by CMS.
In this new reporting requirement, CMS describes what data it needs to collect on rewards and incentive programs in order to track which MAOs are offering such programs and how those programs are structured. The goal is to understand rewards policies and determine whether programs are compliant with its standards and have the proper member protections in place.
Specifically, the new regulations require MAOs to submit the following:
· Do you have a rewards and incentive program(s)?
· What health-related services and/or activities are included in the program?
· What reward(s) may enrollees earn for participation?
· How do you calculate the value of the reward?
· How do you track enrollee participation in the program?
· How many enrollees are currently enrolled in the program?
· How many rewards have been awarded so far?
If you are partnering with a vendor on your rewards and incentive strategy, you should be sure that they help you deliver on this reporting need. The way these requirements are shaping up to be structured requires sophistication in the way that organizations report reward delivery – and at what value. I suggest that plans look for the following when selecting a rewards partner:
· One true data source: Taking advantage of the new Medicare Rewards guidelines requires strategy, outbound and inbound marketing across offline and online channels, fulfillment and many other facets that make it complicated. Ensuring that you can report out on what activities were targeted, members enrolled and the value of those rewards requires a common data set and an end-to-end system to coordinate all of those moving parts. Be sure your partner can manage and help you understand and report on all of these pieces.
· Reporting options: The connection between reward activity, reward value, member and fulfillment can be sliced and diced a number of ways. If you choose to partner with a vendor on your Medicare incentive strategies, the vendor should be equipped with advanced reporting capabilities to be able to provide flexible reporting options against the reporting goals CMS has laid out, but also to help your population health and quality teams achieve their goals.
· Knowledge of regulations: Let’s face it: Your compliance department has its hands full. The smarter your partner can be, the more time compliance saves and the fewer headaches you have. Be sure you select a vendor that knows and understands the relevant regulatory landscape, especially as it relates to new guidance like this rewards and incentive regulation.
This reporting requirement is the latest in CMS’s continuing acceptance and understanding of strategic Medicare rewards and incentive programs. An engagement and rewards platform vendor can be a great asset in both deploying and reporting on rewards and incentive programs for Medicare, but be sure they have the skills to be a partner and not a burden.
Tom Wicka is CEO and cofounder of Novu, an engagement and rewards platform working with the nation’s leading health plans and providers.