On November 8, 2018, the Centers for Medicare and Medicaid Services (CMS) gave notice to QHP Financial Group, Inc. (QHP) that CMS has made a determination to impose intermediate sanctions on Medicare Advantage Prescription Drug (MA-PD) Contract Number: H2773. The sanctions will consist of the suspension of enrollment of Medicare beneficiaries into QHP’s contract and the suspension of all marketing activities to Medicare beneficiaries. These intermediate sanctions will go into effect on November 19, 2018.
From the CMS notification letter:
"For contract years (CY) 2016 and 2017, QHP has reported to CMS a negative net worth of ($8,365,547) and ($11,747,729), respectively. Furthermore, QHP did not report its annual audited financial statement for 2017 until October 19, 2018, which was well beyond the submission deadline of April 30, 2018. Additionally, according to a 2017 CMS financial audit, QHP reported net losses in the amounts of ($2,810,877) for CY 2015 and ($661,327) for CY 2014. These audit results, in combination with the reported negative net worth for CY 2016 and 2017 and QHP’s untimely submission of its 2017 financial statement, have raised substantial concerns as to whether QHP is able to meet its financial obligations on behalf of enrollees.
Affirming these concerns is the volume of complaints that have been filed by providers and enrollees regarding QHP’s failure to pay for services. In addition, CMS conducted a program audit of QHP’s Medicare operations from May 29, 2018 to June 15, 2018. During the audit, CMS found that QHP failed to pay non-contracted providers on time and also failed to timely notify non-contracted providers of claim denial decisions.
Over the past six years, QHP (H2773) has grown to over 4,000 enrollees. CMS is concerned that QHP’s financial condition and compliance with program requirements will continue to decline if it is permitted to continue to enroll beneficiaries. Intermediate sanctions are necessary for QHP to resolve its financial and operational issues without the strain of providing services for additional enrollees."
In the correspondence to QHP, CMS noted that "the sanctions will remain in effect until CMS is satisfied that the deficiencies that are the basis for the sanctions determination have been corrected and are not likely to recur. QHP is solely responsible for the identification, development, and implementation of its Corrective Action Plan, and for demonstrating to CMS that the underlying deficiencies have been corrected and are not likely to recur. "
Read the CMS notice: