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Establishing and implementing necessary structure and procedures
Medicare Compliance Officer advice and consultation
Coordination and cooperation with in-house counsel
Ongoing consultation on a retainer basis
Updating policies, procedures, and forms to meet changing regulatory requirements
Liaison and routine dealings with CMS
Medicare Compliance and Quality Improvement Committee
Performance oversight and Reporting-Legal Issues
Fraud, Waste, and Abuse Policies and Procedures and Control Programs
CMS Monitoring and Reporting Issues
State/Federal Regulatory Issues
State/Federal Regulatory Issues
At the present time, there is a serious question concerning the extent of Federal pre-emption of regulation of insurers with respect to provision of coverage under the Medicare Advantage Program. CMS is requiring that marketing materials be pre-approved before use, and is engaging in the use of "secret shoppers" to determine whether or not the sales and marketing efforts being followed are in compliance with Medicare regulations.
The State Departments of Insurance are increasingly unsatisfied with total Federal oversight of insurers and insurance salesmen on activities normally regulated by the States, and are likely to attempt regulation of these activities in a manner that could raise the prospect of inconsistent regulatory requirements. Until this tension is resolved through developing a pattern of dealings, or litigation if the regulators are unable to resolve any disputes, compliance will require constant attention to regulation at both levels, with an eye to satisfying both sets of regulators.