PUBLIC SUBMISSION | As of: June 22, 2010 Received: June 18, 2010 Status: Draft Category: Health Plan or Association Tracking No. 80b05017 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-0025
CA
Woodland Hills, CA, 91367
Organization: Health Net, Inc.DV Standards Document (p.25) Criteria #6 on p. 25 states 'b. The number of initial assessments calculated for Data Element 13.3 is a subset of number of new members calculated for Data Element 13.1.' This methodology would result in an incomplete count of HRA completion. HRA completion for members that were enrolled at the end of the reporting period may have completed the HRA subsequent to the reporting period given the 90 day window allowed for this requirement. Therefore it is recommended that either 1) Data Element 13.3 extends the measurement period to 90 days after the reporting period so that completion of an HRA within the 90 day required time frame is included in this measure for all newly enrolled SNP members whose effective date of enrollment occurred during the reporting period OR 2 ) The requirement that Element 13.3 be a subset of Element 13.1 is removed so that all HRAs completed during the reporting period be included in this data element regardless of the effective date of enrollment.
Appendix 3 (p.9) Criteria 4 states:
4. Organization accurately calculates the total number of surgeries, including the following criteria:a)Includes all surgeries with dates of service that occur during the reporting period;
b)Includes only surgeries that occur in an acute hospital setting(Data Element 3:1)
But 5.b. states: c) Includes any supplemental information provided by the hospital regarding SRAEs that are confirmed during the reporting period (even if the event actually occurred during a previous reporting period).
Our Comment: There will be no standardization or ability to trend over time or across plans if events from prior periods are included.
The same direction is provided for HACs.
Sampling Instructions (p.5) Will CMS provide alternatives to submission format (other than by CD)?
| CMS-2010-0177-DRAFT-0025.1: | CA |