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Learn more about CMS Updates that may impact your PACE Plan.

Part D Star Ratings Requirement – Dated 6/29/2018

Summary: CMS remind PACE organizations they are not expected to submit Part D Star Ratings data to CMS.  PACE program agreements will be amended to waive this requirement.  CMS will update the Part D PACE applications to reflect this waiver.

Action: Applicable to PACE. Refer to the email for complete details.

 

Release of Medical Loss Ratio (MLR) Reporting Tool for Contract Year 2017 – Dated 6/29/2018

Summary: CMS announced the release of the MLR reporting tool and instructions for submitting the Contract Year 2017 MLR report.  The upload functionality to complete the MLR report will be available in HPMS on November 9, 2018.  Additional guidance and the expected timeline for the MLR reporting submission is provided.

Action: Informational to PACE as PACE is waived of this requirement.

 

Coverage Gap Discount Program: July Participating Labeler Code – Dated 6/29/2018

Summary: CMS will update the manufacturer labeler codes for the Coverage Gap Discount Program by July 1, 2018.  The updates include adding the following:

50261 TherapeuticsMD, Inc.

71045 Achaogen

71336 Alnylam Pharmaceuticals, Inc.

71904 Amicus Therapeutics U.S., Inc.

Action: Although the Coverage Gap Discount Program does not apply to PACE, the participating labeler codes are applicable because only brand name prescriptions with NDCs from these codes are accepted for Part D payment.  Pharmastar has made the necessary software adjustments to accommodate for the update codes.

 

Posting of Quarterly 2018 Plan Benefit Data on www.cms.gov – Quarter 4 – Dated 7/3/2018

Summary: The CMS public website now has the Contract Year 2018 approved plan benefit data for Quarter 4.  The direct URL to the plan benefit data is provided.

Action: Informational to PACE.  

 

Release of the Coverage Gap Discount Program 2013 Benefit Year Closeout Invoice Reports – Dated 7/3/2018

Summary: CMS announced the release of the Coverage Gap Discount Program 2013 Benefit Year Closeout Invoice Reports for manufacturers and Part D sponsors.  The 2013 Benefit Year Closeout Invoice Reports will include data from benefit years 2013, 2012, and 2011.  The release date is July 17, 2018.

Action: Informational to PACE as PACE participants are not eligible to participate in the Coverage Gap Discount Program.

 

Reminder of Opportunities for MMPs, PACE Organizations, and D-SNPs to Effectively Address Opioid Dependency or Misuse among Dually Eligible Beneficiaries – Dated 7/5/2018

Summary: CMS remind plans of the opportunities to prevent, identify, and comprehensively treat opioid dependency or misuse among dually eligible enrollees in the following:

  • Pain Treatment & Prescribing Practices
  • Early Detection and Treatment for Opioid Use Disorder

Action: Applicable to PACE.  Refer to the memo for complete details.

 

Sponsor Access to the Medicare Plan Finder (MPF) Communications Website – Dated 7/6/2018

Summary: CMS discussed the user authorization process for the Medicare Plan Finder Communications Web Portal on Acumen.  Plans will continue to use the web portal provided as a means of distributing information regarding any outliers identified by the QA checks for pricing and pharmacy network data files.  The final 2019 Star Ratings report will be made available after July 27, 2018.

Action: Informational to PACE.  Refer to the memo for complete details.

 

Invitation to Provide Feedback to the Contract Year 2019 Bid Submission – Dated 7/6/2018

Summary: CMS invited all plans to provide feedback on the Contract Year 2019 bid submission process in HPMS.  A list of the specific areas CMS is looking for on comments and suggestions is included.  Plans can provide feedback from July 9, 2018 through July 20, 2018 through the link provided.  

Action: Applicable to PACE. Refer to the memo for complete details.

 

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Quality Assurance Checks for 2019 Data Submitted for Posting on the Medicare Plan Finder Tool – Dated 7/6/2018

Summary: CMS highlighted a list of key information for plans regarding the QA analysis process to ensure pricing and pharmacy data posted to the Medicare Plan Finder are complete and accurate.  In addition, CMS provided updates for the QA analysis process for CY 2019.

Action: Informational to PACE.  Refer to the memo for complete details.

 

Changes Resulting from Federal Register Notice of Public Comment Period for Updated Program Audit and Timeliness Monitoring Data Collection – Dated 7/9/2018

Summary: CMS announced the intend to update the PRA package to include the audit protocols, inclusive of compliance standards that are used to audit sponsor performance.  The documents will be included in the upcoming 30-day notice for the PRA package for public comment.  CMS anticipate the PRA package to be approved by 2019 with intent to be implemented for audit year 2020.  Current audit protocols and record layouts for universes used in 2017 and 2018 will continue to be utilized in 2019. 

Action: Informational to PACE as PACE programs have their own PACE Audit Protocols.

 

Second Round of HPMS Crosswalk Exceptions for Contract Year (CY) 2019 – Dated 7/9/2018

Summary: CMS announced the additional opportunity for plans to request an HPMS crosswalk exception for CY 2019.  Organizations may submit additional crosswalks and modify existing exception requests in HPMS from July 9, 2018 through July 11, 2018.  

Action: Informational to PACE.  Refer to the memo for complete details.

 

Final 2016 Risk Adjustment Deadline and MAO-004 Reports – Update – Dated 7/11/2018

Summary: CMS extended the deadline for the submission of encounter data for Payment Year 2016 to ensure payment accuracy.  The extended deadline will be September 14, 2018.  

Action: Applicable to PACE.  Refer to the memo for complete details.

 

Important Date Reminders

Date

      Item

11:59 PM PT on July 31, 2018

2017 Direct & Indirect Remuneration (DIR) Submission Deadline

11:59 PM PT on July 31, 2018

2013, 2014, 2015, and 2016 DIR Resubmission Deadline

(If any changes or errors to the DIR amount)

Mid-August-

Mid-September 2018*

2017 Attestations of PDE, DIR Data, P2P Reconciliation Payments and Detailed DIR Report Submission Period

January 1, 2019

Preclusion List Requirement Begins

*Subject to change, forthcoming information to be release by CMS.

Please note that this information is provided to you in summary form for general informational purposes only and does not constitute legal or regulatory compliance advice.  It is your responsibility to consult with your Compliance Officer and/or legal counsel to determine applicability of any regulation or standards referenced herein to your organization and/or processes.

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