Inviting the wolves into the hen house
One of the blights on the Medicare Set-Aside (MSA) industry
is the aggressive sales tactics employed by some vendors to generate revenue.
Readers of this blog know that MEDVAL believes that the MSA process is a
consultative, professional service, best performed by highly skilled legal,
medical and financial professionals. However, other firms look at an MSA as a
commoditized widget to be aggressively pursued and sold by a sales force long
on ambition to earn a commission check but short on qualifications or claims
handling ability. Take a look at the
website for the industry’s most active trade organization, the National
Alliance of Medicare Set-Aside Professionals (NAMSAP). Most of the employment listings are for sales
reps with very little required in the way of qualifications.
With the advent of the new reporting requirements found in
the Medicare, Medicaid, and SCHIP Extension Act
(MMSEA), some firms have seized on a new marketing gimmick to drive
revenue and generate claim referrals. In exchange for an exclusive MSA
relationship and maybe a small fee, they will handle all the reporting
requirements for the Responsible Reporting Entity (RRE).
Here is what they don’t tell you…
They have no
experience building or maintaining an electronic interface with the Centers for
Medicare and Medicaid Services
(CMS) or managing an IT project
requiring change management from within a client organization.The
difficulty in compliance with the MMSEA Section 111 reporting requirements is
not interfacing with CMS but gathering the required fields from legacy claims
systems and changing the way information is developed by the claims handler.Once these
firms have a master list of all eligible Medicare beneficiaries, each claims
office can expect a nonstop badgering of front line claims professionals so
that the local “field rep” can meet this month’s sales quota.Offers to
indemnify a payer against CMS penalties are virtually meaningless since several
of these firms failed to live up to the last great marketing gimmick : the “guaranteed MSA”. All that was accomplished by the guaranteed
MSA was an increase in the loss costs of payers due to millions in overfunded
MSAs with a negative net benefit to clients that were oversold and
underserviced. Instead of
having the flexibility to choose a best-of-breed MSA provider, you may now be
now locked-in to higher MSA fees (nothing is really free is it?), questionable
work product and a dysfunctional vendor relationship where the vendor dictates
terms because of the difficulty of
transitioning a CMS reporting relationship once established.
MEDVAL has agreed to act as an agent for a couple of fairly
small regional clients since they don’t have the resources to comply with the
IT challenges. Our internal claims system accepts data transfers from clients
and will be compliant with CMS protocols once they are fully developed.
However, you will never see us market this service as a way
to capture MSA business. We strongly
believe that any sizable claims organization has ample resources to handle this
requirement internally with minimal resources.
Giving an MSA vendor with a large hungry sales force access
to a target rich list of confidential claims data is sort of like leaving the
wolf to guard the hen house.
Concerned about the MMSEA Mandatory Insurer Reporting
Requirements? Need a little help? Call
888-SET-ASIDE or e-mail us at firstname.lastname@example.org.
Medicare Set-Aside Allocation/Arrangement Recommendations
Submissions to Centers for Medicare and Medicaid Services
Pharmacy Benefit Management