PUBLIC SUBMISSION | As of: June 22, 2010 Received: June 18, 2010 Status: Draft Category: Health Care Industry - PI015 Tracking No. 80b053f2 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-0013
MI
Southfield, MI, 48076
Organization: Blue Care Network of Michigan1. Reduce the required amount of information if the health plan is already HEDIS audited as much of the information is duplicative.
2. Review of Part D tech specs could cause a considerable burden on some delegated entities (i.e., PBMs). Consider allowing the PBMs to have an external auditor review those requirements that are applicable and issue a report to the PBM clients (aka plans) which would be acceptable to CMS. More efficient and definitely cost effective.
3. Tech Specs: Procedure Frequency Clarification should be given to when the exclusions apply for each condition. Additionally clarification is requested for items like Procedure Frequency Sections 2.3 and 2.4 which both contain CPT 35472 suggesting that the two buckets are double counting the same procedures