The Managed Care Program Annual Report (MCPAR): A Final Rule Requirement
In its 2016 final rule, the Centers for Medicare & Medicaid Services (CMS) required states to submit an annual managed care program report within 180 days after the end of each contract year. This reporting requirement will become effective for contract periods beginning on or after July 1, 2021. The first reports will be due December 27, 2022.
What Managed Care Clients Should Expect
In an effort to standardize data collected, CMS provided a Microsoft Excel workbook designed to capture required information at the specific state, program, and health plan levels. CMS will collect the data electronically through a web-based submission portal available to states by June 27, 2022, at the latest.
There are ten MCPAR topic areas, and CMS developed a data collection tool that will allow CMS to compare state managed care programs based on standardized data nationwide and identify which states need help managing or improving their programs and maintaining regulatory compliance. With this being an intention of CMS, it may be beneficial for states to consider some level of verification of the MCPAR self-reported data.
MCPAR requires agencies to be responsible for gathering, compiling, and reporting data to CMS for comparative purposes. As with other reported data, this information is subject to review and validation by CMS or other authoritative entities. The following areas must be reported on annually:
- Program enrollment and service area expansions.
- Financial performance.
- Encounter data reporting.
- Grievances, appeals, and state fair hearings.
- Availability, accessibility, and network adequacy.
- Delegated entities.
- Quality and performance measures.
- Sanctions and corrective action plans.
- Beneficiary support system.
- Program integrity.
Experience has taught us that a health plan’s self-reported data carries certain concerns and considerations that merit special attention, especially for states that may not currently be in compliance with the periodic audit requirement. Specifically related to Item 2 above, consider the following:
- Unaudited medical loss ratios (MLRs) have a high risk of misclassified, inflated, or inappropriately-reported MLR components. Inaccurate MLR reporting can cause overlooked capitation payment recoupments and inflated actuarial rate development calculations, which ultimately may impact capitation payments.
- Because health plans often consolidate content, placing disparate data and information together, there exists a high risk of misclassified data. Often, this information is a mix of administrative costs within medical costs (cost of care or related-party cost), which can cause inflated medical costs or inappropriate MLR components.
- Misclassifying quality initiatives and other related costs might cause medical loss to be overstated and may impact capitation payments and MLR remittances.
- Unsupported costs, out-of-period costs, and reallocated costs add complexity to managed care reporting and may increase the chance of errors or inappropriately classified expenses.
For health plans accumulating and reporting these costs, data integrity is pivotal. Health plans must have controls in place to ensure the accuracy of self-reported data, and States should be able to trust that the data is supported and accurate.
How We Can Help
A certified public accounting firm, such as Myers and Stauffer, is the proper entity to provide an unbiased assessment of a health plan’s self-reported data to ensure compliance with accounting standards and federal guidelines. We conduct ourselves according to rigorous professional ethical standards designed to serve the public good. These hallmarks of professional CPA standards define our firm and guide our work.
We have considerable expertise assisting state Medicaid agencies in complying with managed care rules and program oversight, all informed by more than four decades of experience. In fact, auditing governmental health care financial information is our core service.
Just as important, we provide clients a dedicated audit team of trained professionals who have the skill and experience necessary to assist with all facets of MCPAR reporting and oversight. Our team’s breadth of knowledge will help ensure your organization complies with all required regulatory guidance.
 10 Things to Know about Medicaid Managed Care. https://www.kff.org/medicaid/issue-brief/10-things-to-know-about-medicaid-managed-care/