PUBLIC SUBMISSION | As of: June 22, 2010 Received: June 17, 2010 Status: Draft Category: Health Plan or Association - HP010 Tracking No. 80b04988 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-0009
TN
Nashville, TN, 37205
Organization: HealthSpringHealthSpring has reviewed the draft documents and submits the following questions:
1. What does CMS consider the records to be for the sampling unit? For example, the document entitled Medicare Part C and Part D Measure Sampling Instructions for Data Validation shows the Appeals sample size as 150.
2. What "records" are going to be reviewed to validate that the Appeals were processed and classified correctly? How are the auditors going to know if the samples (from the universe of reports numbers) are real appeals and classified counted correctly? The Document Supporting Statement for Paperwork Reduction Act does not address what this documentation will be. All the information just talks about sampling and submitting documentation.
3. Part D realizes there will be other documents that will be supplied; like P&P's, processes and data pull criteria, but we intrepret the 150 sample validation to mean extra documentation that would be reviewed and do not see what that documentation is.
4. Our current PBM, Argus, also provided comments directly to CMS. Bulletin number # D834.