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Exception Requests for Contract Year 2017 MA Application Cycle-Due March 1, 2016– Dated 02/25/2016

Summary: All Exception Requests for the CY 2017 MA Application were due to CMS by March 1, 2016 8p.m. ET. This was the only opportunity for MA applicants to submit Exception Requests.  

Action: Informational to PACE plans, does not apply to PACE as PACE is not required to comply with the CMS network adequacy standards. 


Request for Public Comment on the Proposed Enhanced MTM Model Encounter Data Structure and Pilot Monitoring Measures– Dated 02/26/16

Summary: The release of this memo is to attain public comment on draft specifications for Enhanced Medication Therapy Management (MTM) model encounter data elements. There is a draft attached to the memo that includes specifications for pilot monitoring measures CMMI will calculate to monitor sponsors’ implementation of the model and identity challenges and best practices. Stakeholders are invited to submit comments to until 5:00 p.m. ET, Tuesday, April 26, 2016

Action: Informational to PACE plans. Does not apply to PACE as PACE is waived of the requirements of the MTM program.


Announcement of the May 2016 Software Release– Dated 02/29/16

Summary: CMS continues to implement software improvements to the enrollment and payment systems that support Medicare Advantage and Prescription Drug programs (MAPD). The scheduled release of detailed information is for May 2016. The focus of the release is on improving the efficiency of CMS systems as well as Plan processing.

Action: Applicable to PACE plans. For further information on release changes please refer to the HPMS memo. 


Medicare Advantage/Prescription Drug System (MARx) March 2016 Payment-INFORMATION– Dated 02/29/16


CMS provided information related to the March payment:

  • Coverage Gap Discount (CGD) Invoice Offsets for 2015
  • Special Late Enrollment Penalty (LEP) File
  • Expansion of the PPR Data File

Questions or concerns should be directed to the MAPD Help Desk.

Action: Applicable to PACE plans. For further information on payment related items that may require plan action please review memo.


2016 Medicare Advantage &Prescription Drug Plan Spring Conference & Webcast-Registration is Open– Dated 03/01/16


CMS is pleased to announce that registration is open for the 2016 MAPD Plan Spring Conference & Webcast. The event will be held on Thursday, May 5, 2016 from 9:30 AM-4:30PM EDT as CMS provides important and new information for MA organizations and Part D sponsors. The following topics to be discussed will be:

  • Building Effective Relationships with Your Account Managers
  • Chapter 6: The Part D Formulary Awakens
  • Encounter Data Update
  • Effective Strategies for Addressing Overutilization and Abuse of Prescription Drugs in Medicare Part D
  • Open Q&A Session

Participants planning to attend in person are encouraged to register as there are a limited number of seats.

Action: Informational to PACE plans. Please refer to the memo for more information on how to register by 6pm EDT, Friday, April 22, 2016.


Delay in Enforcement of the Medicare Part D Prescriber Enrollment Requirement to February 1, 2017– Dated 03/01/16

Summary: CMS is delaying enforcement of the Part D Prescriber Enrollment Requirements until February 1, 2017. There is a responsibility to enforce the integrity of this crucial program and basic quality assurance protection for Part D beneficiaries as soon as possible. However, there is also the responsibility to enforce it in a way that minimizes disruption of beneficiaries’ access to needed Part D medications. With the revised date, prescribers will have sufficient time to complete their enrollment activities also this will allow Part D sponsors, PBMs, MAOs offering MA-PDs additional time to finalize the system enhancements needed to comply.  

Action: Applicable to PACE plans. To preview the guidance documents please follow the link provided in the HPMS memo. 


Civil Money Penalty Enforcement Actions for 2015 Program Audits– Dated 03/03/16

Summary: CMS has released the Civil Money Penalties imposed on Part C and Part D Sponsors for violations of Medicare Part C and D requirements found during the plan sponsors’ 2015 Program Audit. These violations were related to failure to comply with one or more Medicare requirements. CMS believes that the significance of these failures adversely affected, or had the likelihood to affect, enrollees. A total of 12 sponsors were issued a CMP during November 2015 through February 2016 based on findings from their 2015 program audit. 

Action: Informational to PACE plans. 


Annual Request for Part D Payment Reconciliation Contact Information– Dated 03/03/16

Summary: Each year Part D sponsors identify contact persons for the Part D payment reconciliation as well as contact persons for their Direct and Indirect Remuneration (DIR) Reports. Part D sponsors will enter this contact information into the Contract Management module of the HPMS for active Part D contracts. Acumen, LLC assist CMS with the Part D payment reconciliation process. Acumen uses contact information from sponsors in order to communicate with certain issues. Contact information must be submitted for each Part D contract number by Friday, April 29, 2016

Action: Applicable to PACE plans. Refer to memo for additional information.


2016 Medicare Part D Low-Income Subsidy (LIS) Income and Resource Standards– Dated 03/03/16

Summary: CMS has attached tables within this HPMS memo for the 2016 Poverty Guidelines for individuals who apply for the low-income subsidy (LIS) for Medicare Part D. CMS is required by law to update the income and resource limits each year. 

Action: Applicable to PACE plans. For further information refer to the memo. 


Q&A Addressing Advance Notice Proposal for Part C Employer Group Waiver Plan Payment– Dated 03/07/16


On February 19th, CMS proposed to change the methodology for Part C payments to Employer Group Waiver Plans. In response to the inquiries regarding the impact of the proposal, the following question and answer have been provided.

Question: Can CMS provide an estimate of the expected impact of the proposed change for Part C payments to EGWPs?

Answer: We estimate that the average 2017 impact for EGWPs of the proposed Part C EGWP payment change is -2.5%. We estimate that average 2017 program-wide impact of the proposed Part C EGWP payment change is -0.4%.

Action: Informational to PACE plans. 


2016 Full Replacement Coordination of Benefits (COB) File–Dated 03/07/16

Summary: This is notification for Part D sponsor staff responsible for the receipt and handling of COB files from CMS on the upcoming annual full replacement file refresh. Between March 21 and March 23, 2016 each Part D plan will receive a full replacement COB file for all enrollees with other coverage. Multiple COB files may be received over a 3 day interval by plans with a large number of Part D enrollees with other coverage. The daily COB process will cease while full replacement files are being generated and therefore will be identifiable between daily COB files per date of receipt and file size.         

Action: Informational to PACE plans. Any record updates occurring March 21-23, will be sent once the daily notification files resume following completion of the full replacement file process.  


PDBM Chapter 6 Reissued– Dated 03/07/16

Summary: An updated Chapter 6-Part D Drugs and Formulary Requirements of the Medicare Prescription Drug Benefit Manual is available at the link below. This version reinserts section 30.2.3, which was inadvertently omitted.

Action: Informational to PACE plans. Review the manual for all updated revisions.


2016 BIN/PCN Listing– Dated 03/08/16

Summary: CMS has posted a list of 2016 Processor ID Numbers/Processor Control Numbers (BIN/PCNS) for Part D Sponsors and pharmaceutical manufacturers. Both 2015 and 2016 lists can be found at

Action: Informational to PACE plans. This data is based on information reported by Medicare Part D sponsors and has not been validated by CMS. 


Long Term Institutionalized Resident Report–Dated 03/09/2016

Summary: The first 2016 LTI Resident Report was distributed to plans on March 8, 2016. Your organizations will only receive a Long Term Institutionalized Resident Report if you have LTI enrollees. This report is distributed to each Part D sponsor through the secure CMS EFT process. This report is based on data from MDS of nursing assessments as of January, 2016.   

Action: Informational to PACE plans who receives the LTI Resident Reports. For further information refer to the memo. 


Coverage Gap Discount Reconciliation for Benefit Year 2014–Dated 03/09/16

Summary: CMS completed the calculations for the 2014 Final Part D Coverage Gap discount Reconciliation. The reports should be available in your mailboxes at the Third Party Administrator Operations as of Thursday, March 10, 2016. If you cannot access these reports, please contact the TPA at 877-534-2772, Option 1. 

Action: Informational to PACE plans. For further information refer to the memo.  


Payment Year (PY) 2012 Overpayment Recovery –Dated 03/09/16

Summary: PY 2012 risk score rerun deadline to submit all PY 2012 (2011 dates of service) deletions to the Risk Adjustment Processing System is Friday, April 8, 2016. The sweep will occur as of April 8, and all deletions received by the deadline will be included in the risk score rerun and subsequent overpayment recovery.    

Action: Applicable to PACE plans. For questions please email and specify “HPMS memo-PY2012 Overpayment Recovery” in the subject line.  


Good Cause Frequently Asked Questions (FAQ) Document–Dated 03/10/16

Summary: CMS’ Medicare Enrollment and Appeals Group has appended the previously posted Frequently Asked Questions document for good cause requests to include information on the authorized representative and operational procedures for submitting reinstatement requests for good cause via the eRPT. This document is for plan use and assistance in implementing and handling the good cause process.

Action: Informational to PACE plans. These documents are located on the MA/Cost and PDP enrollment web pages on Please send any questions to and cc your Account Manager. 


Coverage Gap Discount Reconciliation for Benefit Year 2014-Date Correction –Dated 03/10/16

Summary: On March 9, 2016, CMS released the HPMS memorandum, Coverage Gap discount Reconciliation for Benefit Year 2014. In that memo, it was stated that if the Part D sponsor wished to appeal, the request must be filed and received by Tuesday, March 22, 2016. That date has been corrected and changed to Friday, March 25, 2016.    

Action: Informational to PACE plans. Please refer to the original March 9th memo for information regarding the appeals process. 


Medicare Parts C and D Oversight and Enforcement Group Leadership Announcement–Dated 03/10/16

Summary: This memo is to provide notification of leadership changes within MOEG in the Center for Medicare. Effective April 4, 2016, John Scott will assume the role of Director of the Division of Compliance Enforcement in MOEG. Please welcome John to the MOEG team. Kevin Stansbury will continue to serve as the DCE Deputy Division Director.      

Action: Informational to PACE plans. Refer to memo for further details.  


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.