The Timeliness Monitoring Universes Have Been Submitted. Now what?

By Julie Mason
As of early May, CMS had completed the last round of data-gathering for the 2017 Timeliness Monitoring Project (TMP). Virtually every Sponsor was required to submit data, with the exception of Sponsors who were lucky enough (?!?) to have undergone a CMS program audit in 2016. Sponsors who had not been audited by CMS in the last 4-5 years experienced an important wake-up call for the pitfalls of ODAG and CDAG universe generation. And although CMS has been continually assuring the MA industry that the TMP is not an audit, it sure felt like one—if in miniature—to many of the 156 Sponsors who went through it.
So how and when will Sponsors learn of their results, and what will be the implications of those results? CMS staff offered a few insights at the recent Spring Audit and Enforcement Conference at their headquarters in Baltimore.
CMS anticipates sharing the results of the 2017 TMP this summer (June-July). The plan for now is to release summary data, rather than individual plan data, although the speakers at the conference indicated that Sponsors with results “of concern” would be notified. Unlike CMS program audits, the TMP does not assign point scores to results; it is likely the results will be provided in terms of percentage of timely cases.
As CMS analyzes the collected data, they will be turning an eye to impact on Star Ratings. If the data is accurate and valid, CMS will incorporate it as part of the data integrity reviews for the four appeals measures beginning with the 2018 Star Ratings. To the extent CMS uses data from the TMP in the Star Ratings system, collection of the data will likely occur during the same time each year (e.g., late winter through mid-spring), because CMS data crunchers need the data by early May for the coming year’s Star Ratings. However, CMS may alter the period of data collected (in 2017 they collected February through April 2016 data).
Will TMP affect the CMS program audit protocol in the future? CMS’ Jennifer Smith indicated that if TMP is annual process, as we can expect it will be, then it makes no sense to include timeliness in program audits, as it would be duplicative effort to determine a Sponsor’s timeliness. But she was quick to point out that TMP data is older than data collected in a program audit (i.e., the previous year versus the current year), thus providing advantages to collecting the data both via the TMP and program audits. She also pointed out that the final 2017 audit protocols, recently released, have gotten a 3-year approval under the Paperwork Reduction Act, and thus CMS doesn’t anticipate any significant changes in the audit protocol prior to 2020.
Sponsors are understandably suspicious that CMS will use TMP results to target poor performers for a program audit, but CMS assured conference attendees that currently they do not plan to incorporate TMP results into their risk assessment process to determine who will be audited. This may or may not be true, but given that timeliness is only one of many data points comprising a Sponsor’s compliance, it is unlikely that a Sponsor with poor TMP results but no or few other indicators of poor performance would be elevated on the CMS audit schedule.
Regardless of the speed with which CMS releases results or the possible uses of the data, the TMP further underscores the messages CMS has been hammering the industry with for years:

• Run universes regularly to ensure data integrity;
• Conduct mock audits, not only to practice universe  generation but to identify and correct non-compliance before a CMS audit;
• Timeliness matters.

And if you are struggling to compile complete and accurate universes, you are by no means alone. Seek assistance. MCS has expert resources that have plenty of experience with universes and CMS audits, across all plan types and sizes and over many years.

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