Learn more about CMS Updates that may impact your PACE Plan. FEATURED MEMO: Medicare Part C and Part D Reporting Requirements - Data Validation
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Learn more about CMS Updates that may impact your PACE Plan.


Update to the 2019 Draft Call Letter Part D Coordination of Benefits (COB) Section – Dated 2/8/2018

Summary: CMS proposed the Part D Coordination of Benefits (COB) User Fee amount for 2019 to be $0.1166 at a monthly rate for the first 9 months of the coverage year for a total user fee of $1.05 per enrollee per year.  Plans should account for this COB user fee when developing the 2019 bids.

Action: Informational to PACE.


Contract Year 2019 MA and Part D Bid Pricing Tool Beta Testing – Dated 2/9/2018

Summary: CMS will be conducting beta testing of the draft Contract Year (CY) 2019 Bid Pricing Tool (BPT) on February 15, 2018 until March 2, 2018.  The draft for the CY 2019 bid forms and instructions have been posted to the CMS website.

Action: Informational to PACE.  Refer to the memo for the direct link on the CMS website.


February Actuarial User Group Call – Dated 2/9/2018

Summary: CMS Office of Actuary will host an actuarial user group call on February 22, 2018 to discuss the Contract Year (CY) 2019 bidding and respond to questions from industry actuaries preparing for the CY 2019 bids.

Action: Informational to PACE.  For individuals interested in participating, refer to the memo for complete details on the call information.


Payment Year (PY) 2013 Overpayment Recovery – Dated 2/9/2018

Summary: All PY 2013 deletions to the Risk Adjustment Processing System is due on March 16, 2018 for the PY 2013 risk score rerun.  All deletions received by the deadline will be included in the risk score rerun and subsequent overpayment recovery.

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


2018 Risk Score Reruns for Purposes of Overpayment Recovery – Dated 2/9/2018

Summary: CMS announced the payment years for which CMS intends to rerun risk scores during calendar year 2018 for overpayment recovery. CMS will notify plans at least 30 days in advance of the deadline for submitting deletes for each risk score runs.  

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


New Subcontractor Field Within Contract Management: Data Validation Contractor – Dated 2/13/2018

Summary: CMS requested plans to select a data validation contractor to conduct annual validation of plan-reported data per the Parts C and D reporting requirements. A new data field within HPMS has been created to capture this consultant information.  The path for entering the data is provided.

Action: Informational to PACE as it only applies to Medicare Advantage Plans.


Redesigned “Information and Guidance for Plans” Web Page for Medicare-Medicaid Plans – Dated 2/16/2018

Summary: CMS redesigned the “Information and Guidance for Plans” page for Medicare-Medicaid Plans participating in the Financial Alignment Initiative capitated model demonstrations.  The webpage remains comprehensive but is more user-friendly with new subpages.

Action: Informational to PACE.


Medicare Part C and Part D Reporting Requirements – Data Validation – 30 day Comment Period – Dated 2/16/2018

Summary: CMS is looking for comments on the proposed Medicare Part C and Part D Data Validation of Reporting Requirements data for contract year 2017 for retrospective review in 2018.  Comments are due by February 26, 2016 to CMS.  A link to the proposed draft is included.

Action: Informational to PACE as PACE plans are excluded from the Part C reporting requirements and waived of the Part D reporting requirements.


Updated Announcement Regarding Encounter Data Deadlines for Payment Years 2016 and 2017 Final Reconciliation – Dated 2/16/2018

Summary: CMS announced extended deadlines for the final reconciliation of Payment Years 2016 and 2017 to facilitate the submission of complete encounter data, and improve the accuracy of risk adjustment payments. The encounter data submission deadlines for payment years 2016 and 2017 is included with the anticipated payment months. 

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


Appeals-Related Changes to Prepare for the New Medicare Card Project – dated 2/16/2018

Summary: CMS released guidelines to plans on what type of identifier (HICN or MBI) to use on the reconsideration- and redetermination-related notices, background data forms, and their case file transmittal coversheets.  

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


ESRD and Part D Risk Scores to Support Evaluation of Proposals in Part II of the 2019 Advance Notice – Dated 2/16/2018

Summary: CMS has posted plan-level risk scores on HPMS for PY 2015.  The risk scores are calculated with the ESRD and Part D models discussed in the Part II of the Advance Notice. 

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


Important Date Reminders



January 2018

Sensipar- ESRD Treatment must be included in the ESRD PPS & no longer payable under Part D benefit.

March 4, 2018

HICN to MBI Crosswalk File available via MARx.

April 1, 2018

Medicare Diabetes Prevention Program services to be covered for eligible Medicare beneficiaries.

April 1, 2018

New Medicare Card (Formerly known as SSNRI) to Begin

January 2019

Enforcement Date for the Prescriber Enrollment Requirement

*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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