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[null,"CY2012 Part C Reporting Requirements\nForm # CMS-10261 (OMB# 0938-1054)"]
[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 C","All",null,null,"The Part C Technical Specifications released with this comment request have not been updated with the new reporting requirements for Part C, i.e., Enrollment and Disenrollment reporting requirements. Also, the Notes sections within the Part C Technical Specifications for some requirements were not updated with clarifications that we had received, e.g., for SRAE reporting.  These were not updated for CY2012, nor were the Notes sections updated for 2010 or 2011.  We recommend that going forward, CMS update the Technical Specifications document with all changes and clarifications provided to plans in conjunction with the release of the draft reporting requirements for comment."]
[2,"Part C","Procedure Frequency; Organization Determinations","2; 6","19; 31","In 2012, CMS will receive plans' claims data via the Encounter Data Submission (EDS) process.  Therefore, many of the Part C claim reports, such as Procedure Frequency and Organization Determinations, etc. may be duplicative of the information received through EDS.  We recommend that CMS review the Part C reporting data elements and remove those that are claims-based so that Plans are not required to collect and submit the same data twice.\n"]
[3,"Part C  ","Procedure Frequency ",2,19,"For the Part C Procedure Frequency report, CMS noted as its reasoning for this report that \"Plans with lower than expected rates of these procedures may have barriers to care.\"  We request that CMS provide the \"expected rates\" that are being referred to in the statement and explain how the rates were derived, that is, are they industry standards?  In the alternative, please provide the published source where the rates can be found or a link to the source."]
[4,"Part C  ","Serious Reportable Adverse Events (SRAEs) ",3,24,"The notes section on page 24 of the SRAE Reporting states \"report the SRAE or HAC associated with the most costly procedure and the procedure that ostensibly involves the most resources. That is, prioritize according to cost.\"  However, the data elements conflict with that and require the \"number\" of SRAEs to be reported.  When requesting clarification, CMS notified our plan in February 2011 that we are to report each SRAE that occurred, not the one associated with the most costly procedure.  We request that CMS revise the written requirements to reflect the correct reporting requirements.  The requested update would assure that all plans are consistently reporting the correct SRAE data and would also assure comparability of data across plans."]
[5,"Part C","Plan Oversight of Agents",12,39,"The 10/26/10 Part C Reporting Requirements Technical Specifications, page 39, notes to include all 800 series plans in the Plan Oversight of Agents report.  Please clarify in the specifications and reporting requirements that this direction is incorrect and that plans are not to include 800 series plans in the Part C Plan Oversight of Agents Reporting.\n\n"]
[6,"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."]
[7,"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.\""]
[8,"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.\""]
[9,"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."]