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["Draft CY2012 Part C Medicare Advantage (MA) Reporting Requirements, Form # CMS-10261"]
[]
["Name of Commenting Organization:","UnitedHealthcare"]
["Contact Person Name: ","Barbara Reid"]
["Email: ","barbara_reid@uhc.com"]
["Phone:","715-832-5235"]
["Document (2012 Part C and/or Part D Reporting Requirements)","Report Title","Section #","Page #","Description of Issue/Comment"]
["Part C and Part D","All","All","n/a","We request CMS publish a guide to the validation standards that the data files must pass in order to be accepted by HPMS.  During the upload for Measures, our organization experienced a few rejections based on the validation standards, but did not have clear sight as to what those standards were.  WIthout knowing what the standards are, errors can be difficult to correct, and, once corrected, plans may experience another error based on a different standard during submission of the same file.  If organizations understood the validation standards, files could be quality checked and errors avoided during uploading of the files."]
["Part C and Part D","All","All","n/a","We request CMS provide Plans with the Part C and Part D Reporting outlier statements and calculation methodology for each of the required reports. This information could be used to assist Plans in the interpretation of the Part C and Part D Reporting Requirements and Technical Specifications; support reporting decisions; and support Plans internal identification of potential data issues. If CMS will not provide the calculation methodologies, we request, at a minimum, that the outlier statements be provided."]
["Part C Supporting Statement\nPart D Reporting Requirements","Enrollment and Disenrollment","Part C: 14; Part D: 1","Part C: p 2; Part D: p  5","The Part C and Part D Enrollment and Disenrollment Reporting Requirements Data Element D. notes of the total reported in A, report the number of enrollment requests denied due to determination of the ineligibility to elect the plan (e.g. individual not having a valid enrollment period.). Is CMS requesting the number of enrollments denied by the Plan (40.2.3 - MA Organization Denial of Enrollment) or denied by CMS or both?"]
["Part C Supporting Statement\nPart D Reporting Requirements","Enrollment and Disenrollment","Part C: 14; Part D: 1","Part C: p 3; Part D: p 6","The Part C and Part D Enrollment and Disenrollment Reporting Requirements Data Element M. notes that “of the total reported in A, the number of enrollment transactions submitted using the SEP Election Period code “S” related to change in residence.”  The Plan believes that the information requested in this data element is duplicative of the information CMS already receives as SEP Codes V- permanent changes in residence, W-EGHP, X-Administrative, Y-CMS/Case Worker. Would CMS provide clarification as to why this information is being requested?"]
["Part C Plan Reporting Requirements Technical Specifications\nPart D Reporting Requirements","Employer Group Plan Sponsors","Part - C 7; Part - D XII.","Part C: p 35; Part D: p 23","The Employer Group Plan reporting requires sponsors to provide the current (or anticipated) enrollment for each employer group plan. Employer group plans with no or low membership may retroactively add or remove membership between the time the report is due to CMS and when CMS audits for overdue reporting. The Plan cannot anticipate or control when this membership retroactivity will occur which may cause a gap between CMS and Plan employer group membership records.  When overdue notices were received, it was confirmed that all of the overdue notices received pertained to plans with no membership and/or with no employer groups. In these instances CMS instructed the sponsor to disregard the notices.  However, we are concerned about how these notices will be tracked to ensure that CMS' records accurately capture plan compliance with the reporting timeframes.  We recommend that when sponsors validate there is no EGHP membership or no employer groups, that CMS officially rescind or withdraw the overdue notices."]
["Part C Plan Reporting Requirements Technical Specifications","Procedure Frequency and Serious Reportable Adverse Events","2, 3","19, 24-25","In the notes section, CMS included several references that appear to be applicable to Procedure Frequency reporting and not Serious Reportable Adverse Events reporting.  Page 24 states, \"All SRAEs and HACs are mutually exclusive. If a claim has a code for a hip replacement and knee replacement, the SRAE or HAC would count for both-one SRAE or HAC associated with the hip replacement and one associated with the knee replacement.\"  Page 25 states: \"Total hip replacement and total knee replacement procedures have the same MS-DRS included in Appendix 4. If the procedure identified by MS-DRG 461-462 or 466-470 with no accompanying CPT or ICD-9 CM procedure code, and no other information is available, assign the SRAE or HAC to Total Knee Replacement.\" and \"We currently do not have a code for a kidney and liver transplant, if an enrollee undergoes a kidney and liver transplant, please code as a liver transplant.\"  We request that CMS update/correct the Procedure Frequency reporting notes, if applicable, or provide further clarification as to how these notes apply to SRAE reporting."]
["Part C Plan Reporting Requirements Technical Specifications","Procedure Frequency ",2,21,"In the notes section of Part C Procedure Frequency Reporting, page 21, CMS indicates that \"For Data Elements 2.3 - 2.6, the procedures do not need to occur on the same date of service but do need to occur during the same admission.\"  We request clarification regarding this statement, given that the instructions on page 21 are to count the number of enrollees receiving the specified procedure, not the number of procedures performed."]
["Part C Plan Reporting Requirements Technical Specifications","Procedure Frequency",2,19,"For the Part C Procedure Frequency report, CMS has stated that organizations that will report a subset of the elements are to enter \"0\" into the Procedure Frequency report. This direction suggests that CMS will combine the HEDIS data and the Procedure Frequency data to analyze whether there are barriers to care for these semi-elective procedures. However, HEDIS is a counting of the procedures whereas Procedure Frequency is a counting of the number of enrollees who receive these procedures. Therefore, these data sets are related but not directly comparable. Our recommendation is for CMS to have Plans report all Procedure Frequency data going forward, regardless of whether the similar but incomparable data information is also reported through HEDIS. "]
["Part C Plan Reporting Requirements Technical Specifications","Provider Network Adequacy",4,26,"For the Provider Network Adequacy reporting data elements, please clarify why Geriatrician is not included as a PCP Type, but Pediatrician is included.  If applicable, please correct the PCP types."]
["Part C Plan Reporting Requirements Technical Specifications","Special Needs Plans (SNPSs) Care Management",13,42,"The Special Needs Plans (SNPs) Care Management reporting module on HPMS is set up to require all contracts and PBPs to report, whether or not the H/PBP is filed as a SNP.  This results in unnecessary reporting of \"zeros\" for plans not filed as SNPs.  We recommend the HPMS reporting module be updated for CY 2011 to restrict reporting to only those plans that are filed as Special Needs Plans."]