Hi Jessica,
We have interpreted that to mean anyone in the Compliance team working on Medicare C/D product for any significant part of their assigned duties. Remember that it is a Compliance Program Effectiveness (CPE) audit, so it's about Compliance efforts. We do support other product lines, so for positions such as the Chief Compliance Officer who oversees all of Compliance, what we have done is determine what percentage of total lives covered are for each product line, and report that breakdown as the CCOs time. So, for example, if 35% of your company's total covered lives are in your MA product line, and 65% are in your commercial line, then we report the CCOs time devoted to Medicare C/D as 35%. Most other team members are 100% MA because all they support is MA, but for those who work on both (for example, if a compliance team member supported all of Grievances & Appeals for all product lines), we usually report them with this total covered lives percentage.
Hope that helps!
Merri Beth
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Merri Lavagnino
Executive Director, Compliance & Privacy
Indiana University Health Plans
Indianapolis,IN
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Original Message:
Sent: 11-02-2022 01:46 PM
From: Jessica Sauceda
Subject: CPE Powerpoint- Number and percentage of staff dedicated to Medicare C/D business operations
For the CPE powerpoint presentation part of the requirement is to list: Number and percentage of staff dedicated to Medicare C/D business operations.
Anyone have any insight if this is staff dedicated solely to Medicare C/D operations or if they conduct any Medicare C/D operations?
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Jessica Sauceda
Compliance Supervisor
Portland,OR
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