PUBLIC SUBMISSION

As of: June 22, 2010 Received: June 17, 2010 Status: Draft Category: Health Plan or Association Tracking No. 80b04bb7 Comments Due: June 18, 2010 Submission Type: Web

Docket: CMS-2010-0177
Medicare Part C and Part D Data Validation (42 C.F.R. §422.516g and §423.514g) - (CMS-10305)

Comment On: CMS-2010-0177-0001
Medicare Part C and Part D Data Validation (42 C.F.R. §422.516g and §423.514g): CMS-10305

Document: CMS-2010-0177-DRAFT-0012
OH

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Submitter Information

Name: Keith Pick
Address:

Indianapolis,  OH,  46204

Organization: WellPoint, Inc.

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General Comment

According to the HPMS memo released on November 23, 2009 (Medicare Part C and D Reporting Requirements and Data Validation), CMS indicates that the CY 2010 data validation audits will occur during the period of approximately March 2011 through May 2011.

Based on the answer to question number 26 contained in the November 23, 2009 HPMS memo, it is our understanding that the data validation review of the Benefit Utilization report due August 31, 2011 will be performed prospectively. Additionally, based on the footnote contained on page 7 of this document, CMS indicates that all data validation reviews, with the exception of Part C Benefit Utilization, will be retrospective; however, there are several Part C reports and one Part D report subject to CY 2010 data validation that are due on or after May 31, 2011 (Procedure Frequency, Serious Reportable Adverse Events, Special Needs Plans Care Management, and Long-Term Care Utilization).

Since these reports are due at the end of the projected time that the data validation audits will occur, will CMS also be performing a prospective review of these reports?

Any clarification that you can provide is appreciated.

Thank you,

Keith Pick