Thursday, July 21, 2011

The GP Regulatory landscape, do you know what you don’t know?

The worst place to be in the world of GP compliance these days is to not know what you don’t know!

There may not always be definitive answers, and there will always be gray areas, but venues for dialogue are critical for you to be aware of how the industry, lawyers and consultants are viewing the current landscape.

Our mission at CIS is to foster the discussion in various ways, including our free monthly GP Forum, the GP Compliance Blog, and through our strong support for conferences like IIR’s Medicaid Drug Rebate Program. IIR is always one of the most popular and topical conferences for the GP community. This year its timing of September should make the MDRP Summit a must attend for many manufacturers.


The fall of 2011 should be an interesting time, with the expectation of a Final AMP rule for Average Manufacturer Price, and with anticipated guidance in the Public Health Program, such as patient definition and the proposed user fee. There is layer upon layer of changes in Government Programs that manufacturers have been integrating into their operations and forecasting, such as Part D Discount disputes, Medicaid Managed Care rebates, the industry fee, etc.

It is too much for any one person or one company to be a complete expert in. There is strength in numbers, and when the GP Community comes together for open discussion on the state of the programs, as well as understanding of guidance, we all walk away more informed. It is also essential for our industry to be vocal in our comments to the agencies in this critical rule making period.

Attending IIR’s Medicaid Drug Rebate Program gives you the opportunity to hear the questions, find out if they are the same questions you have, find out where there may be some answers, and furthermore, where there are not answers to at least know how the industry is viewing it. This will give you a shared understanding of the ambiguities which could potentially save your company millions of dollars or as well as avoid compliance risks!

Chris Cobourn, Vice President of Regulatory Affairs
chriscobourn@cis-partners.com




Monday, July 11, 2011

HHS Releases Proposed Regulations for Health Exchanges

Today, HHS released their proposed regulations for how states should run their health insurance exchanges as part of the PPACA. For 75 days, industry groups, consumer advocates, as well as the general public have the opportunity to comment on the draft before the government releases their final regulations. The 200+ pages outlines the rules that must be in place for each exchange, but the question remains: Will states and plans be ready in time?

With an estimated 24 million newly eligibles, we’ve heard of states and health plans scrambling to put together their strategies to comply with the federal law. Your best resource will be to attend the Health Insurance Exchange Congress where health plans, states and the federal government are addressing the opportunities and challenges presented by the implementation of Health Insurance Exchanges. You will learn key strategies from states and plans with existing exchanges and hear firsthand what works and what doesn’t.

Register online to join us today. Receive 25% off the standard registration rate with Priority Code XP1610BLOG when registering online.

To read the complete draft regulations, click here.




Tuesday, July 5, 2011

Hospice care is on the rise along with fraud

Hospice care allows those who are terminally ill to receive pain medicine without receiving treatment to prolong their lives. This has been shown to both extent the life and comfort of the patient while saving money on treatment. However, with pain medication use on the rise, experts are fearful of the rise in fraud. In 2000, Medicare paid $2.9 billion in hospice care bills. In 2009, those cost increased by a whopping $9 billion.

Based on fears of fraud and the drastic increase in budget, Medicare adopted a rule that if an individual stays longer than six months on pain medicine, they will meet a doctor or nurse face-to-face in order to determine if the patient is suffering from a terminal condition. The New York Times wonders if this will cause those who really need palliative care to seek treatment elsewhere. What do you think?

Studies show that almost a third of Medicare’s $327 billion annual budget is spent on end of life care. The Medicare Congress will provide you with strategies to control costs associated with end of life care as well as other expensive populations.