Summary of Responses

Responses to Public Comments on

CMS-10185 - 2007 Part D Reporting Requirements

9/22/06-10/22/06

Background:

Draft 2007 Part D reporting requirements were posted to the Federal Registry beginning on September 22, 2006 for a final 30-day public comment period. This document summarizes the comments and questions received by close of business on October 22, 2006, and our responses to these questions and concerns. Final reporting requirements will be released in November 2006 pending final OMB approval.

Pharmacy & Therapeutics Committee (P&T)

1. CMS received a comment regarding the submission of P&T Committee members for plan reporting purposes. Due to the sensitivity of the P&T Committee member data, this commenter requested CMS to setup a process in which the subcontractor is able to submit this information directly to CMS for reporting purposes on behalf of the Part D plans it supports.

• Response: Changes have been made to this reporting section. Part D contracts will no longer update information regarding changes in P&T committee as part of the Part D reporting requirements. Instead, Part D contracts will be responsible for responding to three questions for each reporting period. The first question will ask if the Part D contract has made changes to their P&T committee membership. If the Part D contract indicates changes have been made to their P&T committee, the second question will ask if these changes have been reflected within the HPMS Contract Management module. Part D contracts who operate under confidentiality agreements will be able to indicate as such, and that changes have been sent to CMS per those agreements.

Call Center Measures

1. A commenter requested CMS allow reporting of call center data at a subcontractor level, since multiple Part D sponsors may be supported by a single call center operational entity. These sponsors would need to report aggregate call center performance results. The request to report call center data at a subcontractor level was made for both the Pharmacy Support line and the Beneficiary Service line.

• Response: This reporting section has been revised to allow data elements to be entered into the HPMS at the Part D Sponsor, Contract level, or Other. The following statement has been added to this section to further address the issues raised by this commenter: “CMS understands call centers may be structured at other levels such as call center operational entities that do not fall into Sponsor or Contract relationships, and it therefore may be appropriate in some cases for these call center operation entities to prepare aggregate data for their clients’ reporting to CMS. Contracts reporting aggregate data from call center operation entities outside of a Sponsor relationship should record the level of reporting as “Other”. It should be noted call center data will be used for performance monitoring and reporting as submitted to CMS. Part D Contracts, therefore, who submit aggregate data will be considered as providing the equivalent call center services as all other Part D Contracts associated with that Sponsor or call center operation entity.”

Licensure and Solvency

1. CMS received a question regarding item G in subsection I, Financial and Solvency Requirements Documentation for Part D PDP Contracts. Item G states Part D PDP Contracts with any state licensure waivers must submit an update on the status of obtaining licensure for each waived state. The commenter requested CMS clarify if there is a specific format and data elements required for submitting these updates.

• Response: There is no specific format and no specific data elements related to this requirement. The update should explain the status of obtaining licensure for each waivered state.

Responses to Public Comments on CY 2007 Reporting Requirements – 11/2006

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