On November 15, 2005, Medicare Part D, the prescription drug coverage program for senior and other eligible citizens, went into effect. Under this program, private health insurance companies and organizations (Plan sponsors) offer insurance coverage for prescription drugs in which Medicare and eligible Medicaid recipients can enroll. CMS contracted with Plan sponsors nationwide to offer the Part D benefits for qualified beneficiaries on January 1, 2006.
The audit contained in this data set, by the accounting firm KPMG, was performed “in accordance with auditing standards generally accepted in the United States of America.”
The objectives were to determine whether CMS controls over payments to Plan sponsors, PDE records, and year-end reconciliation provided reasonable assurance that:
– the inputs that drive the calculation of monthly payments are accurate and complete
– the Risk Adjustment Factor calculations by the Risk Adjustment Processing System are accurate
– monthly payments are accurately calculated and are tracked
– submitted PDE records are valid, accurate, and complete
– PDE data are complete before year-end reconciliation, and
– Direct or Indirect Remuneration (DIR) reporting is accurate and complete.
CMS has designed a layered compliance framework that uses as inputs beneficiary reported complaints, internal data analysis results, audits, and other continuous oversight activities to take compliance action against Plan sponsors when needed. In addition, monthly payments are accurately being calculated and tracked. However, (1) the bid review and audit process needs improvement to ensure that inputs to monthly payments are accurate and complete; (2) controls need to be improved to ensure that submitted PDE records are accurate and complete and PDE data are complete before year-end reconciliation; and (3) improved benchmarks and metrics are needed to ensure the completeness and accuracy of DIR before reconciliation.