2025 Medicare Parts C & D Civil Money Penalty Updates & Rates
Relevant to: PDP, Audit Protocol, Part D
Each week, we scan the latest CMS memos to find the most important ones that apply for PACE programs. Below is a summary of what you need to know.
Disclaimer: The content provided on this site is a summary for informational purposes only, and Grane PBM, Inc. assumes no liability for any errors or omissions in the site’s content. The information does not constitute legal or regulatory advice or replace the original CMS memo. Readers are advised to consult the CMS memo in its entirety and to verify information independently before making any decisions based on this information.
Click here to read the complete memo from CMS.
Introduction
The Centers for Medicare & Medicaid Services (CMS) have released an update regarding the Civil Money Penalty (CMP) amounts for 2025. These updates pertain to Medicare Advantage and Prescription Drug plans. The memo outlines the accrual of standard minimum penalties and includes tables detailing the updated penalty amounts, ensuring compliance and addressing deficiencies effectively. The adjustments reflect changes in the Office of Management and Budget’s (OMB) multiplier to maintain accurate penalty figures.
Key Dates and Deadlines
- Memo Date: May 15, 2025
- Update Year for Accrued and Applied CMP Amounts: 2025
- Previous Updates: 2019, 2022, 2023, and 2024
PACE Compliance
This memo is relevant to PACE programs as it outlines the updated calculations and accruals for Civil Money Penalties (CMPs), which are applicable to organizations under Medicare Parts C and D. As PACE programs participate in Medicare, they need to be aware of these updates to ensure compliance regarding financial penalties for any identified deficiencies.
Plans operating under Part C and D must adhere to the CMS guidelines on CMPs, as outlined in the memo. Failure to comply may result in organizations being subjected to these penalties under the updated amounts for 2025. The outlined methodology was initially announced in 2019 and has been updated yearly, necessitating ongoing attention to these updates to minimize risks associated with non-compliance.
To align with these requirements, organizations need to:
– Review the memo’s tables to understand the updated 2025 penalty amounts for various deficiencies, including per enrollee and per determination penalties.
– Take note of the aggravating factors that could increase penalty amounts, ensuring that all requirements are met to avoid them.
– Monitor the CMS updates annually to ensure continued compliance with the adjusted minimum penalty amounts.
This memo serves as a critical reminder to maintain compliance with the current standards and to be proactive in addressing any areas of potential deficiency.
Required Actions
All Medicare Advantage Organizations, Medicare Advantage – Prescription Drug Plans, Prescription Drug Plans, Section 1876 Cost Plans, and Medicare-Medicaid Plans need to comply with the updated Civil Money Penalty (CMP) amounts as announced by CMS. The organizations should take the following actions:
1. Review the updated 2025 Civil Money Penalty (CMP) amounts and ensure your organization is aware of and understands how these impact your operations and existing deficiencies.
2. Verify compliance practices against the outlined CMP standards and methodology to prevent any deficiencies that could result in penalties.
3. If your organization has questions regarding the CMP updates, contact the appropriate CMS department using the details in the memo or through the designated email.
FAQs
- What are the new standard civil money penalty amounts for Medicare Parts C and D in 2025?
- How did CMS determine the updated 2025 penalty and aggravating factor amounts?
- What is the purpose of the penalty adjustment and accrual process?
- When were the tables for penalty amounts last updated before 2025?
