2019 Part D Misclassifications, Formulary Issues Fueled CMPs

Of the 13 Medicare Advantage and Part D organizations that were subject to 2019 program audits, nearly half received a civil monetary penalty (CMP), with noncompliance in the audit area of Part D formulary and benefit administration (FA) driving fines.

CMS via the Health Plan Management System released the audit scores of the 13 organizations that underwent 2019 Medicare Parts C and D program audits, with scores ranging from 0 to 1.74 (the lower the score, the better the performance). The results included Health Care Service Corp. (HCSC), which was audited in 2018 and 2019 but received a CMP only for 2018.

© 2025 MMIT
Lauren Flynn Kelly

Lauren Flynn Kelly Managing Editor, Radar on Medicare Advantage

Lauren has been covering health business issues since the early 2000s and specializes in in-depth reporting on Medicare Advantage, managed Medicaid and Medicare Part D. She also possesses a deep understanding of the complex world of pharmacy benefit management, having written AIS Health’s Radar on Drug Benefits from 2004 to 2005 and again from 2011 to 2016. In addition to her role as managing editor of Radar on Medicare Advantage, she oversees AIS Health’s publications and manages the health editorial staff. She graduated from Vassar College with a B.A. in English.

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