Medicare Advantage Rewards and Incentives: Are we there yet?

Yes, Medicare Advantage is finally catching up to the rest of the health care industry, and we are now permitted to offer enrollees Rewards and Incentives.

On December 4, 2014, CMS released an HPMS memo titled "Rewards and Incentives Program Guidance" which provides additional guidance related to how Organizations must implement Rewards and Incentives Programs, which, as of July 22, 2014, CMS allows for Part C benefits.

Although the implementation of Rewards and Incentives is no easy task, I think the more pertinent question is how could this new guidance impact your Organization and our industry as a whole? Well, some of that, I think, will remain to be seen as these programs are implemented.

However, I do think there are a few challenges and strategies that we should consider as we're implementing these programs. Here are a few things to mull over as you're ringing in the New Year:

• What is the competitive landscape for Rewards and Incentives, and how will your Organization ensure that it is competitive while still remaining compliant?

• How will your Organization ensure that your Rewards and Incentives program will have an impact on enrollee behavior?

• How will your Organization track information regarding Rewards and Incentives?

• Last but not least, how will your Organization oversee the implementation of your Rewards and Incentives program to ensure compliance?

So, what is the trend? The fact that Medicare Advantage Organizations are now allowed to provide Rewards and Incentives (for Part C benefits) further indicates that CMS' main focus and main objective is the health of the Medicare population -- as it should be, of course.

However, we in the industry should take note -- along with CMS' continued scrutiny via their program audits (and other mechanisms) of those areas that have the potential to cause beneficiary harm, they are also loosening the reigns in certain key areas such as Rewards and Incentives. The objective here is to ensure that Medicare beneficiaries have access to high-quality health care including any incentives that could in fact have a meaningful change in the way that beneficiaries approach their health care.

Betsy Seals is senior vice president of compliance solutions at the Gorman Health Group, where this post originally appeared.