Helaine I. Fingold, a Senior Counsel in the Health Care and Life Sciences practice, in the firm’s Baltimore office, was quoted in Medicare Advantage News and AISHealth, in “On Heels of Secret Shopping Success, CMS May Turn Elsewhere to Find Deficiencies,” by Lauren Flynn Kelly.

Following is an excerpt:

Another area where plans should be careful to ensure accuracy during the CY 2017 AEP is with the summary of benefits (SB) provided to current and potential enrollees, adds Fingold. Although it is a “file and use” document and CMS has granted new flexibility to plans by allowing them to develop their own approach or follow CMS’s model summary, “CMS will certainly be watching closely to ensure that SB information is accurate,” she advises.

“Based on the importance of this document, CMS may adopt a process whereby plans have to self-report SB inaccuracies, similar to that used for the ANOC/EOC,” says Fingold, referring to the Annual Notice of Change and Evidence of Coverage documents that plan sponsors must send to members by Sept. 30 of each year. “This could represent a new area on which CMS could annually issue compliance notices or even enforcement actions, as happens with the ANOC/EOC. Accordingly, plans should take great care in ensuring that the structure of their SB complies with CMS requirements and the benefit and cost-sharing information included is accurate.”

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