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Coverage Gap Discount Program: February Participating Labeler Code Update– Dated 01/28/16

Summary:  CMS will update the list of participating manufacturer labeler codes for the Coverage Gap Discount Program by February 1, 2016. The update includes the following changes:


  • 60923 Sarepta Therapeutics
  • 61874 Actavis Pharma, Inc.
  • 65197 WellSpring Pharmaceutical Corp

69296 Inspirion Delivery Technologies, LLC

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. 


Medicare Advantage/Prescription Drug System February 2016 Payment-Information– Dated 01/28/16

Summary:  CMS provided information related to the February payment:

  • Payment Cleanup to Reverse Incorrect Adjustments with Reason Codes 18/36
  • Late Enrollment Penalty Cleanups-Cleanup #1 and #2
  • 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 the memo. 


Final Risk Adjustment Data Submission Deadline Clarification– Dated 01/29/16

Summary: CMS announced on January 27, 2016, in the HPMS Memo, Risk Adjustment Processing System (RAPS) Diagnosis Cluster Edit-410 Error Code, he risk adjustment data submission deadline for RAPS data submissions has been extended to Monday, February 22, 2016. Several inquiries from MA Organizations were received regarding whether this guidance affects the submission deadline for encounter data. CMS clarified that the risk adjustment data submission deadline for encounter data submissions remains Monday, February 1, 2016.

Action: Informational to PACE plans. 


Changes to Part D Date of Death PDE Editing Effective July 1, 2017– Dated 01/29/16

Summary: Effective July 1, 2017, CMS will modify the current PDE data editing associated with the beneficiary’s date of death. On February 24, 2015, CMS solicited comments on a potential modification to the PDE DOD editing, which in turn helped with the editing modification being put in place. 

Action: Applicable to PACE plans. For further information provided on background, comments and PDE edit changes please refer to the memo. 


Rescheduled-2016 Call Center Monitoring Webinar for Medicare Advantage Organizations, Prescription Drug Plans, and Medicare-Medicaid Plans– Dated 01/29/16

Summary: Due to technical difficulties the January 26, 2016 Call Center Monitoring project webinar was scheduled for Wednesday, February 3, 2016, 1:00-3:00 p.m. The webinar provided and overview of the monitoring studies and allowed the opportunity for questions and answers. 

Action: Informational to PACE plans. For further information please check out the Slide deck on CMS’s webpage. A recording will also be provided on the web page. 


Submission of 2015 Plan Oversight of Agents Enrollment File Data– Dated 02/01/16

Summary: CMS require plans to submit agent/broker-level Plan Oversight of Agents Enrollment File data for Contract Year 2015. The reporting deadline for this data is 02/29/2016

Action: Informational to PACE plans. PACE programs are not authorized to utilize agents and/or brokers for enrollment purposes.


Clarification of Medicare-Medicaid Plan Model of Care Approval Periods– Dated 02/02/16

Summary: All MMPs with MOCs expiring on December 31, 2016 have been notified individually via a tailored memo, as well as an automated HPMS notification, about the requirements for resubmission of a MOC by February 17, 2017. If your organization has not yet been notified, your resubmission is not yet due. For further guidance on this please review the memo. 

Action: Informational to PACE plans. 


E-PACE Application Training – Dated 02/02/16

Summary: CMS announced the release of the new 2016 automated, electronic PACE application. A training session was held on February 4, 2016 to provide PACE organizations and other stakeholders with an overview of the electronic initial application and submission process. The training was recorded and posted to the CMS website. 

Action: Applicable to PACE plans. 


2016 Medicare Advantage and Prescription Drug Plan Audit & Enforcement Conference &Webcast Agenda Topics Solicitation– Dated 02/08/16

Summary: The 2016 Medicare Advantage and Prescription Drug Plan Audit & Enforcement Conference is scheduled for June 16, 2016. The agenda is in the process of being created based on feedback from last year and program enhancements that are currently underway. 

Action: Informational to PACE plans. If you have any ideas for any session topics for this conference please send your feedback to by February 12, 2016, 5:00 PM EST. Please include the title of the HPMS memo in the subject of the email. 


Changes to Application Materials: Removal of References to Code “000”– Dated 02/09/16

Summary: CMS has removed any reference to code “000” from the application materials posted on CMS’s website. MAOs shall not use code 000 to identify providers/facilities on their Health Service Delivery tables. Inserting code 000 may result in network failures during CMS’s review of an MAO’s submitted HSD tables for its contracted provider/facility network.      

Action: Informational to PACE plans.  


Implementation of the Cost Contract Plan Transition Requirements under the Medicare Access and CHIP Reauthorization Act of 2015: Star Ratings and Clarification of Bid Submissions–Dated 02/09/16

Summary: CMS released guidance on Parts C and D Star Ratings and clarifies previous guidance concerning bid submissions associated with the cost contract transition provisions of the MACRA. This memo supplements the December 7, 2015 HPMS memo, Implementation of the Cost Contract Plan Transition Requirements under the Medicare Access and CHIP Reauthorization Act of 2015. 

Action: Informational to PACE plans. 


Additional Guidance-Compliance Program Training Requirements and Audit Process Update– Dated 02/10/16

Summary: On June 17, 2015, CMS issued a HPMS memo entitled “Update-Reducing the Burden of the Compliance Program Training Requirements.” The memo provided guidance about the requirement to accept completion of CMS’ compliance training module on the Medicare Learning Network as the CPE requirement effective January 1, 2016

Action: Informational for PACE plans. 


Issuance of the Revised Draft 2017 Medicare Marketing Guidelines– Dated 02/10/16

Summary: CMS will carefully consider all public comments on the draft release of 2017 Medicare Marketing Guidelines HPMS memo before finalizing the document. Modifications to the current guidelines are presented in red font in this draft version for ease of review. The guidelines are directed at MAOs, PDP sponsors, 1876 Cost-based contractors, demonstration plans, employer and union-sponsored group plans, as well as industry stakeholders and will provide operational guidance on CMS marketing policies. 

Action: Informational to PACE plans. While PACE organizations do not follow the MAPD marketing guidelines, they should be aware of the information.


Announcing publication of PCSP Access Levels to the CMS webpage–Dated 02/11/16

Summary: CMS analyzed the availability of preferred cost sharing pharmacies to Part D enrollees. They issued and HPMS memo on December 4, 2015 asking Part D sponsors to review the data from this analysis, prior to CMS publishing the results. CMS is announcing that it has published information on PCSP access levels for each plan offering a preferred cost sharing benefit structure.

Action: Informational to PACE plans. The data has been posted on the CMS webpage. Please refer to the memo for the link. 


Important Reminders Regarding Contract Year 2017 Medicare Advantage and Prescription Drug Benefit and Related Contract Year 2017 Applications–Dated 02/11/16

Summary: CMS would like to remind all applicants that the Contract Year 2017 Medicare Advantage, Part D Prescription Drug Benefit, and Employer/Union-Only Group Waiver Plan Initial, as well as Service Area Expansion Applications, and Special Needs Plan Proposals submission deadline is 8PM EST on February 17, 2016. All applicants must hit “Final Submit” prior to this deadline in order for the application to be received. CMS would like to remind you after you hit “Final Submit” to go to the submission confirmation page and write down your confirmation number.    

Action: Informational to PACE plans. If you did not receive a confirmation number this means that the application was not received. For further information please refer to the email. 


Agent/Broker Compensation: MARx Test File–Dated 02/09/16

Summary: CMS developed the Agent/Broker Compensation test file for Plans/Part D Sponsors to use in preparing for the upcoming release of the MARx Agent Broker Compensation file. Organizations should use the test types that apply to their plan type and should adjust the record count on the trailer before using the file.    

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


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.