As we approach the home stretch of CMS AEP 2022, we at TrendSource have started to get an idea about the different types of violations occurring at specific touchpoints.
While there is often some consistency year-to-year, with in-person events in particular, we are seeing a wide spectrum of violations. Of course, by running CMS Compliance Audits, companies are able to catch these violations, however big or small they may be, before they are noticed by CMS. Once CMS catches violations, costly punitive action will likely follow.
So today, with just about a month left in AEP 2022, we wanted to run through some of the most common types of violations we are seeing at formal events. While we have noticed trends across all Audit types—phone calls, informal events, formal events, and 1:1 appointments—today we are going to focus on formal events in particular.
After reviewing hundreds of CMS Formal Event Compliance Audits, there are some trends we wanted to share.
First, sales reps are missing easy layups or the low-hanging fruit (chose your metaphor!) when it comes to their formal event presentations. That means to say that they are not covering required topics when giving their presentations before the Q&A begins.
For example, reps are required to cover topics like prescription drug benefits and provider networks. Some sales reps are simply failing to do this—an easily correctible violation when caught by TrendSource, a huge failure with consequences when caught by CMS.
From a sales rep’s perspective, while these violations are senseless and egregious, they are also understandable. It’s been a while since formal presentations have taken place in person, people are out of practice, and new sales reps have joined the force. This is why CMS Compliance Audits are so important, they help turn understandable mistakes into teaching moments, not causes for punitive action.
Additionally, reps sometimes either forget or are otherwise unable to provide required materials for attendees. While this could be the result of failed internal logistics or simple frontline human error, it is imperative that formal presentations always include required materials.
Again, from a rep’s perspective this is understandable. It’s been a while since they’ve been in the field—or maybe it’s their first time—and sometimes things just get forgotten. Also, companies may find challenges in supplying their field reps with required materials because their internal logistics were disrupted during the pandemic.
But regardless of how it happens, such violations must be uncovered and corrected before CMS catches on. Furthermore, running CMS Formal Event Audits helps companies document their due diligence when it comes to CMS Compliance.
While these are the most common violations we are seeing this year, they are just a small slice of the violations TrendSource is currently catching during AEP 2022.
A robust CMS Compliance Audit Program is the only way to guard against costly CMS punitive actions. Violations occur every year, but with formal presentations in particular this year, it seems that the Providers and their sales reps are still getting used to being back in the field.
Fortunately, as people kick of the off the dust and get back into the groove, TrendSource CMS Compliance Audits act as a safety net, helping ensure they do not fall into costly violations.