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

Opportunity to Comment on Draft of Proposed Update to National MMP Enrollment Guidance – Dated 6/1/2018

Summary: CMS updated the MMP National Enrollment Guidance and requested for feedback and comments by June 15, 2018.  A list of the key policy/operational improvements proposed is provided.  The finalized guidance will be effective for contract year 2019.

Action: Informational to PACE.


2017 Medicare Health Outcomes Survey (HOS) Baseline Reports and Medicare HOS-Modified (HOS-M) Reports – Dated 6/1/2018

Summary: CMS announced the availability of the 2017 HOS Cohort 20 Baseline and HOS-M reports and data for plans who had participated.  Each participated PACE organization should examine their results for use in quality improvement activities. 

Action: Applicable to PACE plans who participated in the 2017 Medicare HOS.  To access your organization’s reports, follow the pathway provided.  Refer to the memo for complete details.  


Long-Term Institutionalized Resident Report – Dated 6/5/2018

Summary: The second 2018 LTI Resident Report will be distributed to plans on June 5, 2018.  Organizations will only receive a LTI report if they have LTI enrollees.  The layout of the file and a description of best practices related to plan’s use of the report is provided.  

Action: Informational to PACE plans who receives the LTI Resident Reports.


The Availability of OMHA’s Revised Form OMHA-105 is Requesting Participating in a ALJ Hearing – Dated 6/5/2018

Summary: CMS released the revised OMHA-105 on the Office of Medicare Hearings and Appeals website.  The OMHA-105 is a formed to be used by plans when requesting to participate in the proceedings on a request for ALI hearing under 42 CFR 423.2010.

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


Reminder – Process for Requesting an HPMS Crosswalk Exception for Contract Year (CY) 2019 – Dated 6/5/2018

Summary: CMS remind plans of the HPMS crosswalk exceptions process for CY 2019.  A listing of the crosswalk exceptions is provided.  Any plan crosswalk exception request may be submitted in HPMS from June 5, 2018 through June 6, 2018 5 PM ET.  A second round of crosswalk exceptions will be accepted in July.  Additional guidance regarding the second round will be released later this year.

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


Coverage Gap Discount Program: June Participating Labeler Code – CORRECTION – Dated 6/6/2018

Summary: CMS updated the manufacturer labeler codes for the Coverage Gap Discount Program as of June 4, 2018.  The update included adding the following:

  • 25208 Zydus Pharmaceuticals (USA) Inc.
  • 51660 Ranbaxy Pharmaceuticals 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 updated codes.


Payment Year (PY) 2011 Overpayment Recovery – Dated 6/6/2018

Summary: CMS remind plans of the deadline to submit all PY 2011 deletions to the Risk Adjustment Processing System on July 6, 2018 at 8 PM ET.  All deletions received by the deadline will be included in the risk score rerun and subsequent overpayment for recovery.

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


Release of Streamlined Encounter Data Submission Guidance – Dated 6/11/2018

Summary: CMS consolidated existing guidance on encounter data submission and created a revised website to support MAOs in submission of encounter data.  The following are available to plans:

  • Encounter Data Submission and Processing Guide
  • MA & Part D Communications Handbook
  • Streamlined technical assistance Website:

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


2019 Part D Reporting Requirements – 30-day Comment Period – Dated 6/11/2018

Summary: CMS announced the opportunity for plans to comment on the proposed 2019 Part D Reporting Requirements document.  Comments can be sent by July 8, 2018.  The links to the proposed document and other related forms summarized in the document is provided.

Action: Informational to PACE as PACE is waived of the Part D Reporting Requirements.  


CMS’ Encounter Data Processing System (EDPS) Infrastructure Transition – Second UPDATE – Dated 6/11/2018

Summary: CMS completed the EDPS infrastructure transition and will begin processing encounter files submitted on May 18th in the order they were received.  Plans can expect to receive the MAO-001 and MAO-002 reports beginning June 12th

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


Re-Opening of the 2019 Quality Program Advanced APM Module – Dated 6/12/2018

Summary: CMS reopened the Quality Payment Program Advanced APM module in HPMS until June 22nd. The module will allow plans to request that their payment arrangements receive an Other Payer Advanced APM determination as part of the QPP.  

Action: Informational to PACE as PACE plans can submit a request to HPMS for consideration.  Refer to the email for complete details.


Important Date Reminders



June 29, 2018

2017 PDE Submission Deadline

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-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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