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May 6, 2025



Turn Compliance Challenges into Opportunities: Elevate Your Medicare Strategy! 


The Centers for Medicare and Medicaid Services (CMS) issued 11 Civil Money Penalties (CMPs) in April 2025, most of them due to 2024 CMS program audit results. CMS CMPs have exposed critical compliance issues in Medicare Advantage, Prescription Drug Plans, and PACE programs, leading to hefty penalties and operational setbacks. BluePeak is here to help you navigate these challenges with unmatched expertise. We understand the intricacies of Medicare compliance and are dedicated to helping healthcare organizations navigate these challenges with confidence and precision.


Key Compliance Areas:

Part D Formulary and Benefit Administration

Issue: Errors in eligibility files leading to inappropriate rejection of formulary medications.

Impact: Enrollees experienced delayed access to medications, paid out-of-pocket costs, or never received medications.

Financial Penalty: CMP of $285,476

Transition Policy Administration

Issue: Incorrect transition timeframes due to errors in pharmacy benefit manager systems.

Impact: Enrollees faced inappropriate rejection of medications during transition periods.

Financial Penalty: CMP of $5,800

Prior Authorization and Exceptions Requests

Issue: Failure to effectuate approved prior authorizations, leading to denial of medications.

Impact: Enrollees were denied coverage despite having approved authorizations, resulting in delayed access or out-of-pocket expenses.

Financial Penalty: CMP of $14,152 

Coverage Determinations, Appeals, and Grievances

Issue: Failure to process coverage requests and appeals timely, improper classification of complaints.

Impact: Enrollees did not receive medications timely, paid more for drugs, or did not receive appeal rights.

Financial Penalty: CMP of $20,648

Program for All Inclusive Care for the Elderly (PACE) Program Compliance

Issue: Inadequate documentation and service provision, failure to meet participant needs.

Impact: Participants experienced gaps in care and unmet service needs.

Financial Penalty: Various PACE organizations faced penalties of $47,596 for non-compliance with program requirements

For details about the CMS Part C and Part D Enforcement actions, visit Part C and Part D Enforcement Actions | CMS


Email info@BluePeak.com for tailored solutions that address your unique compliance needs, ensuring that you not only meet regulatory requirements but also optimize your processes for better efficiency and outcomes. Let us help you turn compliance challenges into opportunities for growth and excellence. 

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BluePeak Advisors is a division of Gallagher Benefit Services, Inc.