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

Release of the 2016 Part C and Part D Annual Reports, Public Use File (PUF) Technical Specifications, and PUF files for the Part C and D Reporting Requirements – Dated 5/18/2018

Summary: CMS released the following files on the CMS website:

  • 2016 Part C and Part D Annual Reports of sponsor reporting requirements data.
  • Public Use File (PUF) Technical Specifications of 2016 Part C and D Reporting Requirements Data.
  • 2016 Part C and D PUF.

A link to the files is provided.

Action: Informational to PACE as PACE is excluded from the PUF requirement and Part C reporting requirements.  PACE is also waived of the Part D reporting requirements.


Availability of CY 2019 Additional Demonstration Drug (ADD) Validation File in HPMS – Dated 5/21/2018

Summary: CMS will provide direct access to the Medicare-Medicaid Plan Additional Demonstration Drug Validation File in HPMS starting in CY 2019. The pathway to the file is provided.

Action: Informational to PACE.


2018 Performance Measure Validation Requirements for Medicare-Medicaid Plans – Dated 5/21/2018

Summary: CMS will perform the 2018 Performance Measure Validation (PMV) cycle for ongoing performance measure validation of select core and state-specific measures to ensure the reported data are reliable, valid, complete, and comparable among Medicare-Medicaid Plans.

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


Opening of the 2019 Quality Payment Program Advanced APM Module – Dated 5/24/2018

Summary: CMS included the Quality Payment Program (QPP)Advanced APM module to this year’s HPMS.  The module will provide Medicare Health Plans including Medicare Advantage plans, an opportunity to have their payment arrangements included in the QPP All-Payer program.

Action: Informational to PACE.  Refer to the email and links provided for complete details on the Quality Payment Program.


Contract Year 2019 Agent and Broker Compensation Rate Adjustments Submissions, and Training and Testing Requirements – Dated 5/25/2018

Summary: CMS provided information on the following for plans who will use agents and brokers in CY 2019:

  • Compensation limits
  • Directions for submitting compensation amounts in HPMS
  • Training and Testing Requirements

Organizations using agent/brokers may submit their agent/broker information in HPMS Marketing Module from June 4, 2018 through July 27, 2018 11:59 PM EST.

Action: Informational to PACE as PACE plans are not authorized to utilize agents and/or brokers.


Final Medicare Part D DIR Reporting Requirements for 2017 – Dated 5/30/2018

Summary: CMS provided an overview of the comments and responses as well as the Final Medicare Part D DIR Reporting Requirements for 2017.  Plans can begin to submit the 2017 DIR on June 1, 2018 through 11:59 PM PT on July 31, 2018.  Resubmission for summary DIR reports for prior years 2013 through 2016 will begin on July 1, 2018 through 11:59 PM PT on July 31, 2018.

Action: Applicable to PACE plans. Refer to the memo for complete details on the DIR submission requirements.  For all plans active with Pharmastar in 2017, Pharmastar will provide the DIR data and notify the plan once the reports are available.  Plans are to review their DIR contacts in HPMS and make any necessary updates and changes, if applicable. Please contact your Client Support Specialist if you have any questions.


CY 2019 Initial Actuarial Certification Deadline – Dated 5/30/2018

Summary: As part of the CY 2019 bid submission requirements, an actuarial certification must be submitted via the HPMS actuarial certification module for every Bid Pricing Tool uploaded to HPMS.  The module is now available and all initial certifications are to be completed by June 8, 2018.  If a certification is not submitted via HPMS, the bid(s) will not be considered for CMS review or approval.  

Action: Informational to PACE.  PACE plans should review the status of this requirement with their respective actuaries.


Medicare-Medicaid Plan Provider and Pharmacy Directory Webinar Registration – Dated 5/30/2018

Summary: CMS provided Medicare-Medicaid Plans with details for the upcoming Provider and Pharmacy Directory webinar on June 13, 2018.

Action: Informational to PACE.  For individuals interested in participating, refer to the memo for additional details on how to register for the webinar.


Medicare Advantage/Prescription Drug System (MARx) June 2018 Payment – INFORMATION – Dated 5/31/2018

Summary: CMS provided information about the June payment which is scheduled for June 1, 2018 and may require plan action:

  • Coverage Gap Discount (CGD) Invoice Offsets
  • Postponement of Second 2016 Final Risk Adjustment Reconciliation
  • 2017 Final Risk Adjustment Reconciliation
  • 2013 Overpayment Risk Adjustment Reconciliation
  • FIDE NSP Frailty Factor Update
  • Plan Communication User Guide (PCUG) Updates Coming Soon

Action: Informational to PACE.  Refer to the memo for complete details and items that may be applicable to your plan.


Coverage Gap Discount Program: June Participating Labeler Code – Dated 5/31/2018

Summary: CMS will update the manufacturer labeler codes for the Coverage Gap Discount Program by June 1, 2018.  The updates include adding 25208 Zydus Pharmaceuticals (USA) Inc. and 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.


Important Date Reminders



June 4, 2018

Opioid Strategy Submission Requirement Deadline

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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