{"text_format":"2","workbook":"xls","n_sheets":1,"sheets":["Sheet1"],"not_rendered":{"charts":0,"images":0,"macros":0,"external_links":1,"defined_names":1,"comments":0,"pivot_tables":0},"unopened":[],"bounds":{"document_bytes":16777216,"sheet_cells":100000,"run_cost":"one","rows_first":2000,"rows_last":500,"rows_between":2000,"halvings":0,"cell_chars":16384,"cell_head_chars":4096},"cells_cut":0,"cells_raw":0,"read":"whole","date_system":"1900","formulas":"cached_only"}

{"sheet":"Sheet1","index":0,"n_rows":16,"n_cols":6,"rows_kept":16,"cut":false,"hidden":false,"merged":[],"flags":["formulas_cached_only"]}
[null,"CY2012 Part D Reporting Requirements \nForm # CMS-10185 (OMB# 0938-0992)"]
[null,"Organization Name:","UnitedHealthcare Medicare & Retirement and UnitedHealthcare Community & State"]
[null,"Contact: ","Barbara Reid","Phone: 715-832-5235",null,"Email: barbara_reid@uhc.com"]
[]
["Item #","Document (2012 Part C and/or Part D Reporting Requirements)","Report Title","Section #","Page #","Draft Recommendation"]
[1,"Part D ","Long Term Care (LTC) Utilization and Waste","XI. ",21," Under LTC Waste reporting, Data Element D, there appears to be a typographical error in \"The total ingredient cost of total reported in B.\"  We believe should state \"The total ingredient cost of total reported in C.\"  We suggest correcting the error."]
[2,"Part D ","Long Term Care (LTC) Utilization and Waste","XI. ",21,"Long Term Care (LTC) Utilization and Waste Reporting:\nWe recommend CMS implement the collection and reporting of Long-Term Drugs (LTC) Waste to coincide with the Medicare Part D Final Rule LTC Waste 423.154 concerning the collecting and reporting of unused drugs, which is effective January 1, 2013.  Currently, there is no standard for reporting the information and reporting of LTC Waste - unused drugs - would be a burdensome, manual process for pharmacies.  Reporting prior to standard reporting codes being developed will result in CMS receiving varied, incomparable data.  This has occurred in a previous reporting scenario, for example, LTC rebates were to be reported prior to standard codes being developed which resulted in the report being suspended.  To assure accurate, consistent data is received at CMS, we recommend allowing until the 1/1/2013 effective date for the implementation of LTC Waste Reporting, which would include feedback from pharmacy industry task groups, such as National Council for Prescription Drug Programs (NCPDP) and the development of standard reporting codes. \n    "]
[3,"Part D ","Fraud, Waste and Abuse Compliance Programs","XII.",23,"Reporting of Part D Fraud, Waste and Abuse (FWA) at an incident level is difficult to accomplish when Part D Sponsors/plans are completing the reporting at the contract rather than the Sponsor level.  For example, plans would be reporting the same incident multiple times when a single incident impacts more than one contract.  a.) We request CMS consider re-evaluating how plans are to report FWA.  b.) If Part D Sponsors/plans are to report potential FWA at a contract level, please clarify how  plans are to report FWA incidents/complaints that are not tied directly to a member, and no specific contract number is applicable.\n\n\n"]
[4,"Part D ","Fraud, Waste and Abuse Compliance Programs","XII.",23,"As the Fraud, Waste and Abuse reporting requirements are currently written, there may be duplication of reporting of a single incident if that incident includes more than one type of fraud or abuse.  A fraud incident/complaint is defined as a statement, oral or written, alleging intentional deception or misrepresentation, or, a statement alleging behavior known to be false or deceptive, therefore a statement may contain more than one type of alleged fraud or abuse.  We recommend CMS review the reporting requirements and work with the industry to develop requirements that will minimize the duplicative reporting of incidents/complaints."]
[5,"Part D ","Fraud, Waste and Abuse Compliance Programs","XII.",23,"The CMS HPMS Help Desk recently responded to our question concerning Part D Fraud, Waste and Abuse (FWA) Compliance Programs reporting and noted that plans are not to report 800 series plans in this report. The 12/15/10 Part D Reporting Technical Specifications - FWA Compliance Programs, page 63, notes that \"employer direct plan sponsors are exempt from this reporting section.\"  However, the FWA Reporting Requirements and Technical Specifications do not currently note a specific exemption for 800 series plans.  We recommend CMS clarify in the Part D Reporting Requirements Technical Specifications that both Direct Contract, and 800 series plans are exempt from the Part D FWA Compliance Programs Reporting."]
[6,"Part D ","Fraud, Waste and Abuse Compliance Programs","XII.",23,"The 2/28 due date for the annual Part D Fraud, Waste and Abuse Compliance Programs Reporting conflicts with the business process timeframes for reporting to the MEDIC, state, and local law enforcement. Plans have 60 days from receipt of a potential FWA incident to investigate and report as appropriate to the MEDIC. Therefore, MEDIC reporting may not be completed for late November and December incidents and the FWA report may potentially not include all FWA referrals.  We recommend the Fraud, Waste and Abuse reporting deadline be moved to 5/31 to allow for full and accurate reporting."]
[7,"Part D ","Licensure and Solvency ","XIII.",25,"CMS has deleted Licensure and Solvency from the 2012 reporting requirements and noted that this data is reported in the Fiscal Soundness Module in HPMS.  We suggest CMS consider deleting this report from the 2011 reporting requirements, to clearly define Part D reporting from other plan reporting. "]
[8,"Part C and Part D","All","All",null,"We request that CMS provide a guide explaining the technical requirements for files and edits that occur when uploading the reporting measures data into HPMS.  In the past, data has been rejected during the uploads due to technical edits that are in place.  These technical edits are not transparent to plans performing the data uploads so correct uploading on the first attempt or correcting uploads after they have been rejected is difficult.  For example, there is an Excel template provided within HPMS for reporting the Benefit Utilization data, however, it was not indicated in the upload instructions or in the template itself that the file had to be a tab delimited text file with no header.  The correct instructions and file format had to be obtained from the HPMS Helpdesk.  A guide to the technical requirements and uploading edits that are in place would reduce the amount of error messages when uploading extensive data on the measures and conserve HPMS Helpdesk resources."]
[9,"Part C and Part D","Enrollment  and Disenrollment","I.1",6,"We recommend that Data Element K, the reporting of transactions for initial enrollment period, be removed as CMS has access to this data.  This data is sent by plans during normal enrollment transaction processing under enrollment code \"E.\""]
[10,"Part C and Part D","Enrollment  and Disenrollment","I.1",6,"We recommend that Data Element L, the reporting of transactions for initial coverage election period, be removed as CMS has access to this data.  This data is sent by plans during normal enrollment transaction processing under enrollment code \"I.\""]
[11,"Part C and Part D","Enrollment  and Disenrollment","I.1",6,"We request CMS clarify Data Element P.  Does the data element refer to a beneficiary who moves to a new Part C or Part D Sponsored Plan due to another Sponsor's contract nonrenewal, plan termination or service area reduction?  Or, is the data element capturing a current member of a plan who is moved internally to another plan within the same organization, due to contract nonrenewal, plan termination or service area reduction?  For current members who are moved internally due to contract nonrenewal, plan termination or service area reduction are considered disenrollments, and not enrollments, and are sent to CMS using code \"X-administrative change.\"  In this instance then, CMS has access to the data and we would recommend removing the requirement."]