Medicare Part D Reporting Requirements (CMS-10185)

Medicare Part D Reporting Requirements under 42 CFR section 423.505

CMS-10185 CY2008_092007_for PC

Medicare Part D Reporting Requirements (CMS-10185)

OMB: 0938-0992

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MEDICARE PART D

REPORTING REQUIREMENTS

Contract Year 2008





According to the Paperwork Reduction Act of 1995, no persons are required to respond to a collection of information unless it displays a valid OMB control number. The valid OMB control number for this information collection is 0938-0992. The time required to complete this information collection is estimated to average 59 hours annually per respondent, including the time to review instructions, search existing data resources, gather the data needed, and complete and review the information collection. If you have comments concerning the accuracy of the time estimate(s) or suggestions for improving this form, please write to: CMS, 7500 Security Boulevard, Attn: PRA Reports Clearance Officer, Mail Stop C4-26-05, Baltimore, Maryland 21244-1850.



Updated: 09/17/07









Table of Contents



Introduction


In December 2003, Congress passed the Medicare Prescription Drug Benefit, Improvement and Modernization Act (MMA), allowing coverage of outpatient prescription drugs under the Medicare Part D benefit. In accordance with Title I, Part 423, Subpart K (§ 423.514), the Act requires each Part D Sponsor to have an effective procedure to provide statistics indicating:

  1. the cost of its operations

  2. the patterns of utilization of its services

  3. the availability, accessibility, and acceptability of its services

  4. information demonstrating it has a fiscally sound operation

  5. other matters as required by CMS


The purpose of this document is to assure a common understanding of reporting requirements and how these data will be used to monitor the prescription drug benefit provided to Medicare beneficiaries. CMS will use the following terminology to ensure consistency in these reporting requirements:

  • Part D Sponsor –an organization which has one or more contract(s) with CMS to provide Part D benefits to Medicare beneficiaries. Each contract is assigned a CMS contract number (e.g. H# or S#)

  • Plan – a plan benefit package (PBP) offered within a Part D contract (e.g. Plan ID #)


This document lists reporting timeframes and required levels of reporting. Data elements may be reported at the Plan (PBP) level, the individual contract-level, or Sponsor-level. These requirements will be in effect for Contract Year 2008 and are subject to change at the discretion of CMS. According to Subpart O, sanctions may be imposed on Part D Sponsors who fail to comply with these reporting requirements.


The following criteria were used in selecting reporting requirements:

  1. Minimal administrative burden on Part D Sponsors

  2. Legislative and regulatory authority

  3. Validity, reliability, and utility of data elements requested

  4. Wide acceptance and current utilization within the Industry


Reporting requirements are described in this document for the following areas: Retail, Home Infusion, and Long-Term Care Pharmacy Access, Access to Extended Day Supplies at Retail Pharmacies, Vaccines, Reversals, Medication Therapy Management Programs, Generic Drug Utilization, Home Infusion Utilization, Grievances, Pharmacy & Therapeutics (P&T) Committees/Part D Activities, Transition, Exceptions, Appeals, Overpayment, Pharmaceutical Manufacturer Rebates, Discounts, and Other Price Concessions, Long-Term Care (LTC) Rebates, Licensure and Solvency, Business Transactions and Financial Requirements, and Drug Benefit Analyses.


Each Part D Sponsor shall provide necessary data to CMS to support payment, program integrity, program management, and quality improvement activities. Additional reporting requirements are identified in separate guidance documents throughout the year. Guidance has previously been released for formulary, TrOOP, coordination of benefits, payment and 1/3 audit, and low income subsidy.


Part D Sponsors may also be required to submit other information as defined by requirements in the application, guidances, or other documents (e.g. pharmacy access and formularies) during the annual contract bidding, application, or renewal process. Information is also required to be submitted throughout the contract year as allowable changes are made (e.g. formulary changes).





Part D Reporting Requirements


In each of the sections that follow, the method of submission (e.g. entered into or uploaded via the Health Plan Management System (HPMS)) and the level of reporting are specified following the reporting timeline. Sections that refer to prescriptions should encompass all Part D drugs, including compounded drugs.


For PACE Organizations offering Part D coverage, reporting requirements will be limited to: Vaccines; Generic Drug Utilization; Home Infusion Utilization; Pharmacy & Therapeutics (P&T) Committees (for PACE Organizations utilizing formularies); Transition (for PACE Organizations utilizing formularies); Exceptions (for PACE Organizations utilizing formularies); Overpayment; Pharmaceutical Manufacturer Rebates, Discounts, and Other Price Concessions; and Long-term Care (LTC) Rebates.


MA Organizations and Medicare Cost Plans that offer Part D benefits will be required to comply with all reporting requirements contained herein, with the exception of subsections 1, 2 and 3 of the Licensure and Solvency, Business Transactions and Financial Requirements reporting section.


Data format

Each reporting section provides details regarding data format and calculations pertaining to specific elements. All data should be reported in whole numbers, rounding to the nearest whole number (ex. 1.78 should be rounded to 2), with the following exceptions:

  • MTM section: The number of covered Part D 30-day equivalent prescriptions should be entered to two decimal places

  • Long-Term Care (LTC) Rebates section: Rebate $ per unit received should be entered to four decimal places.



  1. Retail, Home Infusion, and Long-Term Care Pharmacy Access




As outlined in §423.120, Part D Sponsors are required to maintain a pharmacy network sufficient for ensuring access to Medicare beneficiaries residing in their service areas. Part D Sponsors must ensure that they provide convenient access to retail pharmacies, as provided in §423.120(a)(1); adequate access to home infusion (HI) pharmacies, as provided in §423.120(a)(4); and convenient access to long-term care (LTC) pharmacies, as provided in §423.120(a)(5). After their initial pharmacy access submissions are approved at the time of application, Part D Sponsors are responsible for notifying CMS of any substantive changes in their pharmacy network that may impact their ability to maintain a Part D pharmacy network that meets our requirements, as described in section 50 of Chapter 5 of the Prescription Drug Benefit Manual.


Part D Sponsors will be required to submit certain data elements on an annual basis that will allow CMS to evaluate Part D Sponsors’ continued compliance with pharmacy access requirements. For purposes of evaluating compliance with the retail pharmacy access standards, Part D Sponsors should use the CMS reference file that provides counts of Medicare beneficiaries by State, region, and zip code. This reference file is provided by CMS with Part D applications. For purposes of evaluating compliance with the LTC and home infusion pharmacy access standards, CMS will use data elements submitted by Part D Sponsors, as well as information from CMS reference files containing counts of nursing home beds and Medicare beneficiaries by State, region, and zip code. Part D Sponsors having received waivers for any willing pharmacy requirement and/or the retail convenient access requirement after the initial pharmacy access submission will submit certain data elements (C and D) on an annual basis for purposes of determining if those plans still meet CMS standards. CMS reserves the right to request appropriate documentation to support a Part D Sponsor’s submitted pharmacy access data elements (e.g., geo-access reports). CMS evaluation of compliance with pharmacy access standards will be conducted based on point-in-time information about pharmacy networks submitted by Part D Sponsors once per year.


Reporting timeline for Sections A and B only:


Period 1

Reporting Period

January 1 - March 31

Data due to CMS/HPMS

May 31


A. Data elements to be entered into the HPMS at the Plan (PBP) level:

  1. Percentage of Medicare beneficiaries living within 2 miles of a retail network pharmacy in urban areas of a Plan’s service area (State for PDPs and regional PPOs, and service area for local MA-PD plans).

  2. Percentage of Medicare beneficiaries living within 5 miles of a retail network pharmacy in suburban areas (State for PDPs and regional PPOs, and service area for local MA-PD plans).

  3. Percentage of Medicare beneficiaries living within 15 miles of a retail network pharmacy in rural areas (State for PDPs and regional PPOs, and service area for local MA-PD plans).

  4. The number of contracted retail pharmacies in a Plan’s service area (State for PDPs and regional PPOs, and service area for local MA-PD plans) as of the last day of the reporting period specified above.


B. Data files to be uploaded through the HPMS at the CMS Part D Contract level. Part D Sponsors will provide a tab delimited text (filename=Pharmacies_(CONTRACTNAME)_(2008P1).txt replacing ‘(CONTRACTNAME)’ with the Part D Contract’s name containing the following fields:

  1. A list of contracted HI network pharmacies into HPMS as of the last day of the reporting period specified above.

  2. A list of contracted LTC network pharmacies into HPMS as of the last day of the reporting period specified above.

Part D Sponsors will use the templates provided in HPMS for upload of their HI and LTC pharmacy networks.


Reporting timeline for Sections C and D only:


Period 1

Reporting Period

January 1 – December 31

Data due to CMS/HPMS

February 28



C. Data elements to be entered into the HPMS at the Plan (PBP) level for only those Part D Sponsors that own and operate their own pharmacies and have received a waiver of the any willing pharmacy requirement.


  1. Number of prescriptions provided by all pharmacies owned and operated.

  2. Number of prescriptions provided at all pharmacies contracted


D. Data elements to be entered into the HPMS at the Plan (PBP) level for only those Part D Sponsors that own and operate their own retail pharmacies and have received a waiver of the retail pharmacy convenient access standards.


  1. Number of prescriptions provided by retail pharmacies owned and operated.

  2. Number of prescriptions provided at all retail pharmacies contracted.





  1. Access to Extended Day Supplies at Retail Pharmacies

NOTE: This reporting requirement applies only to those Part D Plans that include in their networks mail-order pharmacies offering extended day supplies of covered Part D drugs.


As provided in §423.120 and section 50.10 of Chapter 5 of the Prescription Drug Benefit Manual, Part D Plans that include mail-order pharmacies in their networks must permit enrollees to receive benefits, which may include an extended day supply of covered Part D drugs (for example, a 90-day supply), through a network retail pharmacy rather than a network mail-order pharmacy. Part D Plans must contract with a sufficient number of retail pharmacies so as to ensure that enrollees have reasonable access to the same extended day supply benefits at retail that are available at mail-order pharmacies. Part D Plans must submit data biannually (twice per year) that will allow CMS to evaluate access to extended day supplies at retail pharmacies.


Reporting timeline:


Period 1

Period 2

Reporting Period

January 1 - June 30

July 1 – December 31

Data due to CMS/HPMS

August 31

February 28


Data elements to be entered into the HPMS at the Plan (PBP) level:

  1. The number of contracted retail pharmacies that are contracted to dispense an extended day supply of covered Part D drugs.





  1. Vaccines


For monitoring purposes, Part D Sponsors will be responsible for reporting several data elements related to their reimbursement of vaccines, demonstrating their implementation of CMS requirements regarding vaccine access detailed in section 60.2 of Chapter 5 of the Prescription Drug Benefit Manual.


Reporting timeline:


Quarter 1

Quarter 2

Quarter 3

Quarter 4

Reporting Period

January 1 -

March 31

April 1 -

June 30

July 1 -

September 30

October 1 -

December 31

Data due to CMS/HPMS

May 31

August 31

November 30

February 28


Data elements to be entered into the HPMS at the Contract level:


  1. The total number of Part D vaccines processed during the time period specified above, regardless of the method used to process the claim as described in B through F below.

  2. The number of Part D vaccines administered in a clinic setting (e.g. physician’s office) where the beneficiary retrospectively files paper receipts for reimbursement of the vaccine during the time period specified above.

  3. The number of vaccines adjudicated through network pharmacies during the time specified above. (Including those vaccines processed by the pharmacy and submitted electronically).

  4. The number of vaccines processed through a paper enhanced process, where the provider used or navigated a process that facilitated out-of-network access during the time period specified above.

  5. The number of vaccines processed through an internet based web tool.

  6. The number of vaccines processed during the time period specified above through a process not described in data elements B through E.



  1. Reversals


Part D Sponsors will be responsible for reporting data elements related to claim reversals. Information on claim reversals will serve as a component in the monitoring of Part D operational functions


Reporting timeline:


Quarter 1

Quarter 2

Quarter 3

Quarter 4

Reporting Period

January 1 -

March 31

April 1 -

June 30

July 1 -

September 30

October 1 -

December 31

Data due to CMS/HPMS

May 31

August 31

November 30

February 28



Data elements to be entered into the HPMS at either the Contract or Plan (PBP) level:

  1. The number of out-of-cycle pharmacy transactions with reversal as the final disposition, which were adjudicated during the time period specified above. [The term "out-of-cycle" refers to the individual billing/processing cycle of each organization.  Each organization determines its own payment cycle. An out-of-cycle reversal occurs if a prescription is filled and adjudicated, and then, outside the Part D Sponsor’s billing cycle, the pharmacy reverses the claim. Part D Sponsors must report to CMS the total number of (electronic, paper and manual) pharmacy claims ending with a reversed status. Those with a partial reversal as the final disposition should also be included.]




Note: Reversed claim records must be maintained (the number of elements retained per record should at a minimum be equivalent to those of the prescription drug event record), and upon request, submitted to CMS.


  1. Medication Therapy Management Programs


The requirements stipulating that Part D Sponsors provide Medication Therapy Management Programs (MTMP) are described in Title I, Part 423, Subpart D, § 423.153. For monitoring purposes, Part D Sponsors will be responsible for reporting several data elements related to their MTMP. Data will be manually submitted in HPMS, or uploaded in a data file.


  1. Data elements to be entered into the HPMS at the Contract level.


Data related to the identification and participation in the MTMP will be submitted according to the following timeline (note: Period 2 encompasses one full year):



Period 1

YTD

Reporting Period

January 1 -

June 30

January 1 -

December 31

Data due to CMS/HPMS

August 31

February 28


  1. The method used to enroll beneficiaries into the MTMP. Method of enrollment may be opt-in, opt-out, a combination of opt-in and opt-out, or other. This will be selection from a drop-down box. If “other” is selected, a description will be required as a text field.

  2. The number of beneficiaries who met the eligibility criteria for the MTMP in the specified time period above.

  3. The total number of beneficiaries who participated in the MTMP at any point during the time period specified above. This should be a longitudinally cumulative total, and be a subset of the number of beneficiaries who met the criteria for the MTMP in the specified time period.

  4. The total number of beneficiaries who discontinued participation from the MTMP at any time during the specified time period above. This should be a subset of the total number of beneficiaries who participated in the MTMP in the specified time period.

  5. The number of beneficiaries who discontinued participation from the MTMP due to death at any time during the specified time period above. This should be a subset of the total number of beneficiaries who discontinued participation from the MTMP in the specified time period.

  6. The number of beneficiaries who discontinued participation from the MTMP due to disenrollment from the Plan at any time during the specified time period above. This should be a subset of the total number of beneficiaries who discontinued participation from the MTMP in the specified time period.

  7. The number of beneficiaries who discontinued participation from the MTMP at their request at any time during the specified time period above. This should be a subset of the total number of beneficiaries who discontinued participation from the MTMP in the specified time period.

  8. The number of beneficiaries who discontinued participation from the MTMP for a reason not specified in data elements E-G during the specified time period above. This should be a subset of the total number of beneficiaries who discontinued participation from the MTMP in the specified time period.

  9. The number of beneficiaries who declined to participate in the MTMP during the specified time period above. This should be a subset of the number of beneficiaries who met the criteria for the MTMP in the specified time period.

  10. The number of beneficiaries whose participation status in the MTMP is pending during the specified time period above. This should be a subset of the number of beneficiaries who met the criteria for the MTMP in the specified time period and should only apply to period 1.

  11. For beneficiaries participating in the MTMP as of the last day of the reporting period specified, provide the prescription cost of all covered Part D medications on a per MTMP beneficiary per month basis. This should be a currency field, rounded to the nearest dollar. The numerator represents the total prescription drug costs. The total prescription cost should be limited to covered Part D medications and be calculated using gross drug cost as follows: (Ingredient Cost Paid + Dispensing Fee + Sales Tax). This is based on the sum of all Part D covered prescriptions that were dispensed within the reporting period specified for each beneficiary participating in the MTMP as of the last day of the reporting period. This includes both MTMP beneficiary cost sharing and Part D costs paid. The denominator represents the total number of member months for the MTMP participating beneficiaries. These member months should include all months the beneficiary was enrolled in the plan during the reporting period specified, not only the months that the beneficiary enrolled in the MTMP.

The following equation also describes this calculation

  1. For beneficiaries participating in the MTMP as of the last day of the reporting period specified, provide the number of covered Part D 30-day equivalent prescriptions on a per MTMP beneficiary per month basis. This should be a numeric field.


This numerator should be calculated by first summing days supply of all covered Part D prescriptions dispensed for beneficiaries participating in MTMP as of the last day of the reporting period, and dividing by 30 to determine the number of 30 day equivalent prescriptions dispensed.  The denominator represents the total number of member months for the MTMP participating beneficiaries.  These member months should include all months enrolled the beneficiary was enrolled in the plan during the reporting period specified, not only the months that the beneficiary enrolled in the MTMP. 



The following equation also describes this calculation:


  1. Data file to be uploaded using Gentran or Connect Direct at the Contract level.

More information regarding the upload process will be forthcoming.



YTD

Reporting Period

January 1 - December 31

Data due to CMS/HPMS

February 28


The file will contain the following fields for beneficiaries identified as being eligible for the Medication Therapy Management Program:


Beneficiaries Eligible for MTMP Record Layout

Field Name

Field Type

Field Length

Field Description

HICN

CHAR

REQUIRED

10

The Health Insurance Claim Number (HICN) or unique identifier of each beneficiary identified to be eligible for MTMP in the reporting period.

Beneficiary first name

CHAR

REQUIRED

30

The first name of each beneficiary identified to be eligible for MTMP in the reporting period.

Beneficiary middle initial

CHAR

REQUIRED

1

The middle initial of each beneficiary identified to be eligible for MTMP in the reporting period.

Beneficiary last name

CHAR

REQUIRED

30

The last name of each beneficiary identified to be eligible for MTMP in the reporting period.

Beneficiary date of birth

DATE

REQUIRED

10

The date of birth of each beneficiary identified to be eligible for MTMP in the reporting period. This should be a date field (mm/dd/yyyy).

LTC Enrollment

CHAR

REQUIRED

1

For each beneficiary enrolled in MTMP, indicate if the beneficiary was a long-term care (LTC) resident for the entire time they were enrolled in MTMP. This should be either Y (yes) or N (no).

Date of MTMP enrollment

DATE

REQUIRED

10

For each beneficiary identified to be eligible for the MTMP in the reporting period, who enrolled in MTMP, the date MTMP enrollment began. This should be a date field (mm/dd/yyyy).

Date MTMP participation was declined

DATE

REQUIRED

10

This should be a date field (mm/dd/yyyy).

Date participant discontinued MTMP

DATE

REQUIRED

10

For each beneficiary who enrolled in MTMP and then discontinued participation, the date their participation ended. This should be a date field (mm/dd/yyyy).

Reason participant discontinued MTMP

TEXT

REQUIRED

23

For each beneficiary with a MTMP disposition status of discontinued participation, the reason for discontinuation. Reasons for discontinuation may be one of the following: Death; Disenrollment from Plan; Request by beneficiary; or Other. This should be a text field.




  1. Generic Drug Utilization

Cost control requirements for Part D Sponsors are presented in Title I, Part 423, Subpart D. Accordingly, Part D Sponsors will be responsible for reporting data elements needed to monitor utilization of generic drugs (defined by Title I, Part 423, Sub-Part A, § 423.4).


Reporting timeline:


Quarter 1

Quarter 2

Quarter 3

Quarter 4

Reporting Period

January 1 -

March 31

April 1 -

June 30

July 1 -

September 30

October 1 -

December 31

Data due to CMS/HPMS

May 31

August 31

November 30

February 28


Data elements to be entered into the HPMS at the Plan (PBP) level:

  1. The total number of paid claims for Part D generic drugs (regardless of days supply) with dates of service during the specified reporting period identified above. First DataBank or Medispan generic drug classifications will be used to identify generic drugs.

  2. The total number of Part D paid claims (regardless of days supply) with dates of service during the specified reporting period identified above.



  1. Home Infusion Utilization

On a quarterly basis, Part D Sponsors will be required to report data related to home infusion drug utilization. Home infusion drugs are products administered by IV in settings for which these products are not covered by Part B. These data will be monitored by CMS for purposes of assessing enrollee utilization of and access to home infusion therapy. Appendix A of Chapter 6 of the Prescription Drug Benefit Manual contains a list of common Part D-covered home infusion drugs. However, Appendix A does not represent an exhaustive list of Part D-covered home infusion drugs and should be used simply as a reference for Part D Sponsors to develop their lists of home infusion drugs.


Reporting timeline:


Quarter 1

Quarter 2

Quarter 3

Quarter 4

Reporting Period

January 1 -

March 31

April 1 -

June 30

July 1 -

September 30

October 1 -

December 31

Data due to CMS/HPMS

May 31

August 31

November 30

February 28



Data elements to be entered into the HPMS at the Contract level:

  1. The number of Part D beneficiaries receiving Part D-covered home infusion drugs dispensed by any of its network providers as part of a bundled service under a Part C supplemental benefit in the time period specified above (if applicable).   

  2. The total claims associated with Part D-covered home infusion drugs dispensed by any of its network providers as part of a bundled service under a Part C supplemental benefit in the time period specified above (if applicable).




  1. Grievances


Title I, Part 423, Subpart M of the regulation includes regulations that require Part D Sponsors to maintain grievance information. All plans (PBPs) will be responsible for reporting data related to grievances received.


A grievance is defined as any complaint or dispute, other than one that involves a coverage determination, expressing dissatisfaction with any aspect of the operations, activities, or behavior of a Part D organization, regardless of whether remedial action is requested. Examples of subjects of a grievance provided in the solicitation for applications include, but are not limited to, timeliness, appropriateness, access to, and/or setting of services provided by the PDP, concerns about waiting times, demeanor of pharmacy or customer service staff, a dispute concerning the timeliness of filling a prescription, the accuracy of filling the prescription or enrollment/disenrollment issues or recognition of low income subsidy (LIS) eligibility problems.


Part D Sponsors are required by the regulations to track and maintain records on all grievances received orally and in writing. Grievance data, requested herein by CMS, should be reported based on the date the grievance was received by the Plan (PBP), not the date the event or incident that precipitated the grievance occurred. Multiple grievances by a single complainant should be tracked and followed as separate grievances. Plans may report grievances in the categories as determined by the Plans after initial investigation.  Plans should not dismiss or exclude any grievances filed by beneficiaries or their appointed representatives from this reporting section. 


Reporting timeline:


Quarter 1

Quarter 2

Quarter 3

Quarter 4

Reporting Period

January 1 -

March 31

April 1 -

June 30

July 1 -

September 30

October 1 -

December 31

Data due to CMS/HPMS

May 31

August 31

November 30

February 28


Data elements to be entered into the HPMS at the Plan (PBP) level:

  1. For the time period identified above, the number of fraud and abuse grievances received related to Part D. A fraud grievance is a statement, oral or written, alleging that a provider, pharmacy, pharmacist, PBM, Plan, Plan Agent or broker, or beneficiary engaged in the intentional deception or misrepresentation that the individual knows to be false or does not believe to be true, and the individual makes knowing that the deception could result in some unauthorized benefit to himself/herself or some other person. An abuse grievance is a statement, oral or written, alleging that a provider, pharmacy, pharmacist, PBM, Plan, Plan Agent or broker or beneficiary engaged in behavior that the individual should have known to be false, and the individual should have known that the deception could result in some unauthorized benefit to himself/herself or some other person.

  2. For the time period identified above, the number of enrollment/disenrollment grievances received related to Part D. Examples include, but are not limited to, discrimination in the enrollment process, enrollment information and/or identification cards not being received by beneficiaries in a timely manner, and disenrollment requests not being processed in a timely manner.

  3. For the time period identified above, the number of benefit package grievances received related to Part D. Examples include, but are not limited to, beneficiary cost sharing, pricing co-insurance issues and issues related to coverage during the coverage gap period.

  4. For the time period identified above, the number of pharmacy access/network grievances received related to Part D. Examples include, but are not limited to, network pharmacy refusing to accept a beneficiary’s card and network/non-network pharmacy concerns.

  5. For the time period identified above, the number of marketing grievances received related to Part D. Examples include, but are not limited to, marketing materials or promotional messages by sales representatives that include misrepresentations or false/misleading information about plans and benefits, overly aggressive marketing practices, and discriminatory practices identified in marketing materials or through oral/written promotional messages.

  6. For the time period identified above, the number of customer service grievances received related to Part D. Examples include, but are not limited to, grievances regarding services provided by the pharmacist/pharmacy staff, plan or subcontractor representatives, or customer service representatives.

  7. For the time period identified above, the number of confidentiality/privacy grievances received related to Part D. Examples include, but are not limited to, potential violations of medical information privacy standards by the plan or pharmacy.

  8. For the time period identified above, the number of quality of care grievances received related to Part D. Examples include, but are not limited to, grievances received from beneficiaries or Quality Improvement Organizations (QIOs) regarding quality of care.

  9. For the time period identified above, the number of exception grievances received related to Part D. An example of an exception grievance is one which is filed because an enrollee’s request to have their coverage determination expedited was denied.

  10. For the time period identified above, the number of appeal grievances received related to Part D. An example of an appeal grievance is one which is filed because an enrollee’s request to have a redetermination expedited was denied.

  11. For the time period identified above, the number of other grievances received related to Part D not falling into one of the categories described above.

  12. For the time period identified above, the total number of grievances received related to Part D.

  13. For the time period identified above, the total number of LIS grievances received related to Part D. This number should be based on the beneficiary’s LIS status at the time of filing the grievance.





  1. Pharmacy & Therapeutics (P&T) Committees/ Provision of Part D Functions


In addition to satisfying and maintaining P&T committee requirements described in §423.120, Part D Sponsors will be responsible for providing information to CMS relating to changes made during a contract year to their P&T committees on a periodic basis. CMS recognizes the importance of maintaining confidentiality of these records. Additionally, CMS will provide methods other than HPMS data submission for those Part D Sponsors with contractual limitations in providing these data.


Part D Sponsors are also responsible for providing information to CMS relating to the organizations responsible for providing specific functions. This information must be updated on a timely manner if changes occur. On a quarterly basis, Part D Sponsors must attest if changes have occurred, and if they have been communicated to CMS.


Reporting timeline:


Quarter 1

Quarter 2

Quarter 3

Quarter 4

Reporting Period

January 1 -

March 31

April 1 -

June 30

July 1 -

September 30

October 1 -

December 31

Data due to CMS/HPMS

May 31

August 31

November 30

February 28


  1. Data elements to be entered into the HPMS at the Contract level:

  1. Indicate if there have been changes in P&T committee membership during the time period specified above.

  2. If changes have occurred, indicate if these changes have been reflected within the Contract Management module. For those Sponsors operating under confidentiality agreements, indicate if these changes have been sent to CMS per those agreements.


  1. Data elements to be entered into the HPMS at the Contract level:

  1. Indicate if there have been changes to the organizations providing Part D functions during the reporting period.

  2. If changes have occurred, indicate if these changes have been reflected within the Contract Management module on the Part D Data page within the Organizations Providing Part D Functions table.



  1. Transition


As described in §423.120(a)(3) and section 30.4 of Chapter 6 of the Prescription Drug Benefit Manual, Part D Plans must provide for an appropriate transition process for new enrollees who were prescribed non-formulary Part D drugs. For purposes of CMS oversight, Plans (PBPs) will be responsible for reporting various data elements related to minimum plan transition process timeframes on an annual basis.


Reporting timeline:



Quarter 1*


Reporting Period

January 1- March 31

Data due to CMS/HPMS

May 31

*Only one quarter of data will be collected annually


Data elements to be entered into HPMS at the Plan (PBP) level:


  1. The minimum number of days supply the Plan’s transition policy provides for its one-time, temporary fill for enrollees in the retail setting. (NOTE: This must be at least 30 days, unless the enrollee presents a prescription written for less than 30 days).

  2. The minimum number of days, beginning on the enrollee’s effective date of coverage, in a plan’s transition process for enrollees in the retail setting. (NOTE: This must be at least 90 days.)

  3. The minimum number of days supply the Plan’s transition policy provides for its temporary fill (with multiple refills as necessary) for enrollees in the LTC setting. (NOTE: This must be at least 31 days, unless the enrollee presents a prescription written for less than 31 days).

  4. The minimum number of days, beginning on the enrollee’s effective date of coverage, in a plan’s transition process for enrollees in the LTC setting. (NOTE: This must be at least 90 days.)

  5. After the minimum transition period has expired, the minimum number of days supply the Plan provides to LTC enrollees for an emergency supply of non-formulary Part D drugs while an exception is being processed (NOTE: This must be at least 31 days, unless the enrollee presents a prescription written for less than 31 days).

  6. The maximum number of business days after a temporary transition fill within which the Plan will send a written transition notice via U.S. first class mail. (NOTE: This must be 3 business days or less.)


  1. Exceptions


Title I, Part 423, Subpart D includes regulations regarding formulary and tier exceptions, and exceptions to established drug utilization management programs. Plans (PBPs) that utilize prior authorization or step therapy edits as utilization management tools (including for non-formulary exceptions) will be responsible for reporting several data elements related to these activities. Prior authorization requests/approvals that relate to Part B vs. Part D coverage should be included in this reporting.


Reporting timeline:


Quarter 1

Quarter 2

Quarter 3

Quarter 4

Reporting Period

January 1 -

March 31

April 1 -

June 30

July 1 -

September 30

October 1 -

December 31

Data due to CMS/HPMS

May 31

August 31

November 30

February 28


Data elements to be entered into the HPMS at the Plan (PBP) level:

  1. The number of pharmacy transactions rejected due to failure to complete step therapy edit requirements in the time period specified above.

  2. The number of pharmacy transactions rejected due to need for prior authorization (not including first pass step therapy edits or early refills) in the time period specified above.

  3. The number of pharmacy transactions rejected due to quantity limits in the time period specified above.

  4. The number of prior authorizations requested for formulary medications in the time period specified above (not including first pass step therapy edits, early refills, or quantity limits).

  5. The number of prior authorizations approved for formulary medications, of those submitted in the time period specified above (not including first pass step therapy edits, early refills, or quantity limits).

  6. The number of exceptions requested for non-formulary medications in the time period specified above (not including early refills).

  7. The number of exceptions approved for non-formulary medications, of those submitted in the time period specified above (not including early refills).

  8. The number of tier exceptions requested in the time period specified above (not including first pass step therapy edits or early refills).

  9. The number of tier exceptions approved, of those submitted in the time period specified above (not including first pass step therapy edits or early refills).

  10. The number of quantity limit exceptions requested in the time period specified above (not including early refills).

  11. The number of quantity limit exceptions approved, of those submitted in the time period specified above (not including early refills).



  1. Appeals


Title I, Part 423, Subpart M includes regulations regarding coverage determinations and appeals under Part D. As defined in §423.560, an appeal is any of the procedures that deal with the review of adverse coverage determinations made by the Plan on the benefits the enrollee believes he or she is entitled to receive, including a delay in providing or approving the drug coverage (when a delay would adversely affect the health of the enrollee), or on any amounts the enrollee must pay for the drug coverage. These procedures include redeterminations by the Plan and reconsiderations by the independent review entity (IRE). Redeterminations or reconsiderations may result in reversal or partial reversal of the original decision.

  • Example of a full reversal of an original decision: Non-formulary exception request approved upon redetermination for drug and quantity prescribed.

  • Example of a partial reversal of an original decision: Non-formulary exception request approved upon redetermination for drug, but full quantity prescribed is not approved.


CMS will request appeal data as part of the monitoring of a Plan’s availability, accessibility, and acceptability of its services.


Reporting timeline:


Quarter 1

Quarter 2

Quarter 3

Quarter 4

Reporting Period

January 1 -

March 31

April 1 -

June 30

July 1 -

September 30

October 1 -

December 31

Data due to CMS/HPMS

May 31

August 31

November 30

February 28


Data elements to be entered into the HPMS at the Plan (PBP) level:

  1. The number of appeals submitted for standard redetermination in the time period specified above. (Do not include those appeals that were submitted as expedited redeterminations and were not granted expedited status. )

  2. The number of appeals submitted for expedited redetermination in the time period specified above.

  3. The number of appeals submitted for expedited redetermination that were granted expedited status in the time period specified above.

  4. The number of appeals submitted for standard redetermination withdrawn by the enrollee in the time period specified above.

  5. The number of appeals submitted for expedited redetermination withdrawn by the enrollee in the time period specified above.

  6. The number of redeterminations in the time period specified above resulting in full reversal of original decision.

  7. The number of redeterminations in the time period specified above resulting in partial reversal of original decision.

  8. The number of adverse redeterminations in the time period specified above due to insufficient evidence of medical necessity from enrollee’s prescribing physician. Examples of insufficient evidence of medical necessity may include, but are not limited to, when the plan does not receive the information, or the information received does not support medical necessity.

  9. The number of appeals submitted for IRE reconsideration in the time period specified above due to inability to meet timeframe for coverage determination.

  10. The number of appeals submitted for IRE reconsideration in the time period specified above due to inability to meet timeframe for redetermination.

  11. The number of IRE decisions for standard reconsideration in the time period specified above resulting in full reversal of original coverage determination or redetermination.

  12. The number of IRE decisions for standard reconsideration in the time period specified above resulting in partial reversal of original coverage determination or redetermination.

  13. The number of IRE decisions for expedited reconsideration in the time period specified above resulting in full reversal of original coverage determination or redetermination.

  14. The number of IRE decisions for expedited reconsideration in the time period specified above resulting in partial reversal of original coverage determination or redetermination.

  15. The number of IRE decisions for standard reconsideration in the time period specified above resulting in upholding of original coverage determination or redetermination.

  16. The number of IRE decisions for expedited reconsideration in the time period specified above resulting in upholding of original coverage determination or redetermination.


  1. Overpayment


Part D Sponsors will be responsible for reporting data related to overpayments associated with Part D benefits. An overpayment occurs when a Part D Sponsor erroneously makes a payment in excess of the amount due and payable under the Part D drug benefit. Examples would include overpayments a plan makes to pharmacies, sub-contractors, or PBMs for claims payment. This information is necessary to ensure that overpayments are being identified and recouped appropriately.


Reporting timeline:


Period 1

Period 2

Reporting Period

January 1 -

June 30

July 1 – December 31

Data due to CMS/HPMS

August 31

February 28


Data elements to be entered into the HPMS at the Contract level:

  1. For the time period identified above, the total overpayment dollars identified to be recouped by the Contract (i.e., any funds recovered from any entity it has overpaid, including, pharmacies, providers, Pharmaceutical Benefit Managers, etc.)

  2. For the time period identified above, the total overpayment dollars recouped by the Contract.



  1. Pharmaceutical Manufacturer Rebates, Discounts, and Other Price Concessions


Part D Sponsors will be responsible for reporting multiple data elements related to rebates. These data will be monitored as components of a Part D Sponsor’s operational costs. CMS recognizes the importance of maintaining confidentiality of these records.


Rebates, discounts, and other price concessions will be reported at either the CMS Part D Sponsor or Contract level. Reporting will not be combined by the subcontractor PBM to include multiple Part D Sponsors’ data. For example: (1) national Part D sponsors with multiple regional plans contracting independently or through a PBM will report rebates from the level of the national Part D sponsor; (2) regional or local Part D sponsor whether utilizing subcontractor PBM or not report at the Part D sponsor specific level; (3) PBM providing Part D coverage outside of a subcontractor role will report rebates at the PBM level. Rebate information should be summarized for each drug, rolled up to include multiple strengths, package sizes, dosage formulations, or combinations. The quarterly reported totals are not cumulative YTD totals.


Reporting timeline:


Quarter 1

Quarter 2

Quarter 3

Quarter 4

Reporting Period

January 1 -

March 31

April 1 -

June 30

July 1 -

September 30

October 1 -

December 31

Data due to CMS/HPMS

September 30

December 31

March 31

June 30


Data files to be uploaded through the HPMS at the CMS Part D Sponsor or Contract level as specified below. HPMS will provide an option to report “No Data to Report” for Part D Sponsors or Contracts that have no rebate or discount/price concessions data; those Sponsors will not upload data files.

  1. Part D Sponsors/Contracts will provide a tab delimited text file (filename=REBATES_(SPONSORNAME)_(2008Q#).txt, replacing ‘(SPONSORNAME)’ following the below file layout.

Pharmaceutical Manufacturer Rebate File Record Layout


Field Name

Field Type

Field Length

Field Description

Manufacturer Name

CHAR REQUIRED

100

For each rebate, provide the contracting manufacturer name. This should be a




character field.

Drug Name

CHAR REQUIRED

100

For each rebate, provide the drug name. This should be a character field.

Rebates Received

NUM REQUIRED

12

For each unique manufacturer/drug combination, provide the rebate amount received in the reporting period specified.

- Limit to 999999999999, no decimals, can be a negative number.

- Zero should be entered in the fields if no rebate was received in the reporting period specified.

Pending Rebates

NUM REQUIRED

12

For each unique manufacturer/brand name combination, provide the rebate amount requested for the reporting period specified but not yet received (if applicable).

- Limit to 999999999999, no decimals, can be a negative number

- Zero should be entered in the fields if no rebate was requested but not received for the reporting period specified.

Prior Rebates

NUM REQUIRED

12

For each unique manufacturer/brand name combination, provide the rebate amount received that is associated with a prior reporting period (if applicable).

- Limit to 999999999999, no decimals, can be a negative number

- Zero should be entered in the fields if no rebate was received that is associated with a prior reporting period.


  1. It is expected that the file specified above will summarize most rebate information. However, for all non-rebate discounts, price concessions, or other value adds such as gift-in-kind or other programs (e.g., coupons or disease management programs specific to a Part D Sponsor), Part D Sponsors will provide an additional tab delimited text file (filename=DISCOUNTS_( SPONSORNAME)_(2008Q#).txt, replacing ‘(SPONSORNAME)’ with the Part D Sponsor’s name and ‘(2008Q#)’ with the year and quarter number) following the below file layout.


Discounts and Other Price Concessions File Record Layout


Field Name

Field Type

Field Length

Field Description

Manufacturer/ Company Name

CHAR

REQUIRED

100

List the name of each manufacturer for whom there is an associated discount, price concession, or other value add.

Description


CHAR

REQUIRED

250

Describe the discount, price concession, or other value adds.

Value


NUM

REQUIRED

12

Provide the value of the discount, price concession, or other value adds.

  1. 0 is not an allowable value


Justification


CHAR

OPTIONAL

4000

For each discount, price concession, or value add, provide a justification for receipt.

  1. Long-Term Care (LTC) Rebates


As described in the CMS 2008 Call Letters, Part D Sponsors must require disclosure of access/performance rebates or other price concessions received by their long-term care (LTC) network pharmacies designed to or likely to influence or impact utilization of Part D drugs. The term “access/performance rebates” refers to rebates manufacturers provide to pharmacies that are designed to prefer, protect, or maintain that manufacturer’s product selection by the pharmacy or to increase the volume of that manufacturer’s products that are dispensed by the pharmacy under its formulary (referred to as “moving market share”). As evidence that they are managing and monitoring drug utilization, Part D Sponsors must report these data to CMS for oversight. CMS recognizes the importance of maintaining confidentiality of these records. 

Access/performance rebates received and reported by pharmacies will be reported at either the CMS Part D Sponsor or Contract level.  Data should include rebates received for all Part D drugs, not limited to formulary/covered drugs. Rebate information should be reported for each applicable NDC. The quarterly reported totals are not cumulative YTD totals.  


Special reporting cases:

  • LTC pharmacy is not required to report rebates: Sponsors may exercise discretion for requiring rebate reporting from LTC pharmacies that serve less than 5% of LTC beds in an area (“area” is defined as the state in which the LTC pharmacy is licensed.). Sponsors should list the LTC pharmacy NCPDP number in the report, leave the Manufacturer, Drug name and Rebate unit fields blank, and in the Technical Notes field, enter "Not required to report".

  • LTC pharmacy is noncompliant in reporting rebates: Sponsor should list that LTC pharmacy NCPDP in the report, leave the Manufacturer, Drug name and Rebate unit fields blank, and in the Technical Notes field, enter "Noncompliant".


Reporting timeline:


Quarter 1

Quarter 2

Quarter 3

Quarter 4

Reporting Period

January 1 -

March 31

April 1 -

June 30

July 1 -

September 30

October 1 -

December 31

Data due to CMS/HPMS

September 30

December 31

March 31

June 30


Data files to be uploaded through the HPMS at the Part D Sponsor or Contract level as specified above.


Part D Sponsors/Contracts will provide a tab delimited text file (filename=REBATES_LTC PHARMACIES_(CONTRACTNAME)_(2008Q#).txt, replacing ‘(CONTRACTNAME)’ with the Part D Sponsor’s name and ‘(2008Q#)’ with the year and quarter number) containing the following fields.

LTC Rebates File Record Layout

Field Name

Field Type

Field Length

Field Description

LTC Pharmacy

Name

CHAR REQUIRED

100

For each rebate, provide the name of the LTC pharmacy.

NCPDP Number

CHAR REQUIRED

7

Indicate the contracted LTC pharmacy NCPDP number. This field should be a 7 character long string using 0 – 9.

NPI Number

CHAR OPTIONAL

10

Indicate the contracted LTC pharmacy NPI (National Provider Identifier) number.

NDC

CHAR REQUIRED

11

Provide the 11-digit NDC associated with this rebate.

Manufacturer

Name

CHAR REQUIRED

100

For each rebate, provide the contracting manufacturer name.

Drug Name

CHAR REQUIRED

100

For each rebate, provide the brand name.

Rebate $ per unit received

NUM REQUIRED

17

Provide the contractual per unit rebates received during the reporting period (cash basis) associated with the listed drug.

  • Limit to 999999999999.9999, can also be a negative number


Technical Notes

CHAR OPTIONAL

4000

Provide any technical notes regarding the LTC pharmacy rebate calculations.

  1. Licensure and Solvency, Business Transactions and Financial Requirements


Title I, Part 423, Subpart I includes regulations regarding Licensure and Solvency. Part D Sponsors and will be responsible for reporting multiple data elements and documentation related to their licensure and solvency and other financial requirements. Employer/Union Direct Contract PDPs (Direct Contract PDP) will be responsible for reporting multiple data elements and documentation related to their solvency and other financial requirements. Direct Contract PDPs are employers or unions that directly contract with CMS to offer a Part D plan exclusively to the employer’s/union’s retirees. Some data will be entered into the HPMS and other information will be mailed directly to CMS. Documentation requirements are listed separately for Part D PDPs and Direct Contract PDPs. These data will be used to ensure Part D PDPs and Direct Contract PDPs continue to be fiscally solvent entities.


  • Subsection 1. Financial and Solvency Requirements Documentation - Part D PDPs

  • Subsection 2. Financial and Solvency Requirements Documentation – Direct Contract PDPs

  • Subsection 3. Financial and Solvency Requirements HPMS data– Part D PDPs and Direct Contract PDPs


Reporting timeline:


Quarter 1

YTD

Quarter 2

YTD


Quarter 3

YTD

Annual

Reporting Period

January 1 -

March 31

January 1 -

June 30

January 1 -

September 30

January 1 -

December 31

Data due to CMS/HPMS

May 15

August 15

November 15

120 days after the end of the calendar year or within 10 days of the receipt of the Annual Audited F/S whichever is earlier.


I. Financial and Solvency Requirements Documentation for Part D PDP Contracts:

  1. According to the quarterly time periods specified above, Part D PDP Contracts that are licensed will mail the following completed Health Blank form pages directly to CMS:

  • Jurat

  • Assets

  • Liabilities, Capital and Surplus

  • Statement of Revenue and Expenses

  • Capital and Surplus Account

  • Cash Flow

Note: CMS will accept a copy of the Health Blank form submitted to the state in its entirety.

  1. According to the quarterly time periods specified above, non-licensed Part D PDP Contracts will mail un-audited financial statements, which convey the same information contained in the Health Blank form, directly to CMS. An alternative for non-licensed Part D PDP Contracts would be to complete the Health Blank pages as prescribed in A. above.

  2. According to the quarterly time periods specified above, non-licensed Part D PDP Contracts will mail documentation showing that an insolvency deposit of $100,000 is being held in accordance with CMS requirements by a qualified financial institution.

  3. According to the quarterly time periods specified above, Part D PDP Sponsors not licensed in any state must submit documentation that demonstrates they possess the allowable sources of funding to cover projected losses for the greater of 7.5% of the aggregated projected target amount for a given year or resources to cover 100% of any projected losses in a given year. This documentation should include a worksheet indicating how they arrived at the aggregated projected target amount. Pro-forma financial statements including the balance sheet, income statement and statement of cash flows projecting through the next 12 months by quarter. Enrollment projections through the next 12 months by quarter. Guarantees, letters of credit and other documents essential to demonstrating that the funding for projected losses requirement has been met must also be included.

  4. All Part D PDP contracts will mail a copy of their independently audited financial statements (which are statutory based or GAAP based) with a management letter within one hundred twenty days following their fiscal year end or within 10 days of receipt of those statements, whichever is earlier directly to CMS. Licensed entities may not report under GAAP for a period longer than 36 months.

  5. All Part D PDP Contracts will mail a copy of an Actuarial Opinion by a qualified actuary within one hundred twenty days following their fiscal year end directly to CMS. The opinion should address the assumptions and methods used in determining loss revenues, actuarial liabilities, and related items.

  6. According to the quarterly time periods specified above, Part D PDP sponsors with any state licensure waivers must submit an update on the status of obtaining licensure for each waived state.

  7. Per § 423.514 each Part D sponsor must report to CMS annually, within 120 days of the end of the fiscal year, significant business transactions, between the Part D sponsor and a party in interest.

Documentation submitted should include the following:

  1. A description of the transaction or transactions taking place with the party in interest.

  2. Identification of the party in interest and an explanation of how that party meets the definition of a party in interest.

  3. The costs incurred during the fiscal year relating to the transactions between the party in interest and the Part D sponsor and what those costs would have been if incurred at fair market value. If the costs incurred exceed fair market value, provide an explanation justifying that the costs are consistent with prudent management and fiscal soundness requirements.

  4. Combined financial statements for the Part D plan sponsor and a party in interest if 35% or more of the costs of operation of the Part D sponsor go to a party in interest, or 35% or more of the revenue of a party in interest is from the Part D sponsor.

Part D PDP Contracts’ Documentation should be mailed to the following address:

Centers for Medicare & Medicaid Services

Attn: Part D Licensure & Solvency

Mail Stop C1-25-04

7500 Security Boulevard

Windsor Mill, Maryland 21244


II. Financial and Solvency Requirements Documentation for Direct Contract PDPs:

  1. According to the quarterly time periods specified above, Direct Contract PDPs will mail un-audited financial statements directly to CMS.

  2. According to the quarterly time periods specified above, Direct Contract PDPs will mail documentation showing that an insolvency deposit of $100,000 is being held in accordance with CMS requirements by a qualified financial institution (unless CMS waived this requirement in writing with respect to the sponsor).

  3. Direct Contract PDPs will mail a copy of their independently audited financial statements with a management letter within one hundred twenty days following their fiscal year end or within 10 days of receipt of those statements, whichever is earlier directly to CMS.

  4. All Direct Contract PDPs will mail a copy of their credit rating (or, if they have no credit rating, a Dun & Bradstreet report) on a quarterly basis directly to CMS as follows:

For Quarter 1: May 15th

For Quarter 2: Aug. 15th

For Quarter 3: Nov. 15th

For Quarter 4: Feb. 15th

  1. All Direct Contract PDPs will mail an ERISA Sec. 411(a) attestation directly to CMS by February 15th.  See 2008 Solicitation for Applications for Employer/Union Direct Contract Prescription Drug Plan (PDP) Sponsors, Appendix IV, Sec. E.4 for explanation of this attestation.


All Direct Contract PDP Documentation should be mailed to the following address:

Centers for Medicare & Medicaid Services

Attn: Financial Solvency Reporting

Mail Stop C1-22-06

7500 Security Boulevard

Windsor Mill, Maryland 21244

III. Financial and Solvency Requirements data elements to be entered into HPMS – For Part D PDP Contracts / Direct Contract PDPs:


Data to be entered at the Part D Contract level per NAIC #. Each Contract-NAIC# entity will be listed under each contract.

  1. Total assets as of the end of the quarterly reporting period identified above. This should be a currency field.

  2. Total liabilities as of the end of the quarterly reporting period identified above. This should be a currency field.

  3. Total cash as of the end of the quarterly reporting period identified above. This should be a currency field.

  4. Total cash equivalents as of the end of the reporting period identified above. This should be a currency field.

  5. Total current assets as of the end of the quarterly reporting period identified above. This should be a currency field.

  6. Total current liabilities as of the end of the quarterly reporting period identified above. This should be a currency field.

  7. Total revenue as of the end of the quarterly reporting period identified above. This should be a currency field.

  8. Total expenses as of the end of the quarterly reporting period identified above. This should be a currency field.

  9. Total administrative expense as of the end of the quarterly reporting period identified above. This should be a currency field. NOTE: Direct Contract PDPs are waived from this element

  10. Total net income as of the end of the quarterly reporting period identified above. This should be a currency field.

  11. Drug benefit expenses (excluding administrative expenses) as of the end of the quarterly reporting time period. Drug benefit expenses are paid claims costs which would be comprised of negotiated costs and dispensing fees less member share. This should be a currency field.

  12. Drug benefit revenues as of the end of the quarterly reporting period. Drug benefit revenues would include premiums, CMS subsidies, rebates and other reinsurance. This should be a currency field.


  1. Drug benefit analyses


Part D Sponsors must provide enrollees with coverage of benefits as described within §423.104. For the purposes of CMS review, Plans (PBPs) will be required to report multiple data elements related to their provision of Part D benefits. HPMS will display each Plan’s benefit design for integration with the data reported by Part D Sponsors. If a Plan does not have a coverage gap, the Plan should list the number of people who are pre-catastrophic in the data element D (non-LIS) and E (LIS) fields, and then indicate zero in the data element F (non-LIS) or G (LIS) fields. If a PBP does not have a deductible, HPMS will not display data fields B or C.


Reporting timeline: Part D Sponsors will provide data on a monthly basis to CMS.


Quarter 1

Quarter 2

Quarter 3

Quarter 4

Reporting Period

1/1 – 1/31

2/1 – 2/28

3/1 – 3/31

4/1 – 4/30

5/1 – 5/31

6/1 – 6/30

7/1 – 7/31

8/1 – 8/31

9/1 – 9/30

10/1

10/31

11/1

11/30

12/1

12/31

Data due to CMS/

HPMS

3/31

4/30

5/31

6/30

7/31

8/31

9/30

10/31

11/30

12/31

1/31

2/28


Data elements to be entered into the HPMS at the Plan (PBP) level:

  1. HPMS will display each Plan’s benefit design (e.g. defined standard, enhanced alternative)

  2. The total number of non-LIS enrollees in the deductible phase as of the last day of the month.

  3. The total number of LIS enrollees in the deductible phase as of the last day of the month. [List all LIS beneficiaries for all subsidy levels.]

  4. The total number of non-LIS enrollees in the pre-initial coverage limit phase as of the last day of the month. (If a Plan does not have a coverage gap, the Plan should list the number of people who are pre-catastrophic in this field, and then indicate zero in the data element F.)

  5. The total number of LIS enrollees in the pre-initial coverage limit phase as of the last day of the month. (If a Plan does not have a coverage gap, the Plan should list the number of people who are pre-catastrophic in this field, and then indicate zero in the data element G.) [List all LIS beneficiaries for all subsidy levels.]

  6. The total number of non-LIS enrollees in the coverage gap as of the last day of the month. (If a Plan does not have a coverage gap, the Plan should list the number of people who are pre-catastrophic in data element D, and then indicate zero in this field.)

  7. The total number of LIS enrollees in the coverage gap as of the last day of the month. (If a Plan does not have a coverage gap, the Plan should list the number of people who are pre-catastrophic in data element E, and then indicate zero in this field.) [List all LIS beneficiaries for all subsidy levels.]

  8. The total number of non-LIS enrollees in the catastrophic coverage level as of the last day of the month.

  9. The total number of LIS enrollees in the catastrophic coverage level as of the last day of the month. [List all LIS beneficiaries for all subsidy levels.]


Table 1. Summary of Reporting Elements

Note: this summary table is for quick reference use only. Please refer to the respective detailed sections for full definitions, timelines, reporting level, and submission procedures.

Section

Section

Element

Format

Frequency

HPMS

I.

Retail, Home Infusion, and Long-Term Care Pharmacy

Percentage of Medicare beneficiaries living within 2 miles of a retail network pharmacy in urban areas of a Plan’s service area (State for PDPs and regional PPOs, and service area for local MA-PD plans).

Numeric

Annually

Yes

Percentage of Medicare beneficiaries living within 5 miles of a retail network pharmacy in suburban areas (State for PDPs and regional PPOs, and service area for local MA-PD plans).

Numeric

Annually

Yes

Percentage of Medicare beneficiaries living within 15 miles of a retail network pharmacy in rural areas (State for PDPs and regional PPOs, and service area for local MA-PD plans).

Numeric

Annually

Yes

The number of contracted retail pharmacies in a Plan’s service area (State for PDPs and regional PPOs, and service area for local MA-PD plans) as of the last day of the reporting period specified above.

Numeric

Annually

Yes

Pharmacies_(CONTRACTNAME)_(2008P1)

Tab delimited text file

Annually

Yes

II.

Access to Extended Day Supplies at Retail Pharmacies

The number of contracted retail pharmacies that are contracted to dispense an extended day supply of covered Part D drugs.

Numeric

Semi-annually

Yes

III.

Vaccines

The total number of Part D vaccines processed regardless of the method used to process the claim.

Numeric

Quarterly

Yes

The number of Part D vaccines administered in a clinic setting (e.g. physician’s office) where the beneficiary retrospectively files paper receipts for reimbursement of the vaccine.

Numeric

Quarterly

Yes

The number of vaccines adjudicated through network pharmacies. (Including those vaccines processed by the pharmacy and submitted electronically).

Numeric

Quarterly

Yes

The number of vaccines processed through a paper enhanced process, where the provider used or navigated a process that facilitated out-of-network access.

Numeric

Quarterly

Yes

The number of vaccines processed through an internet based web tool.

Numeric

Quarterly

Yes

The number of vaccines through a process not described in data elements B through E.

Numeric

Quarterly

Yes

IV.


Reversals


Total number of out-of-cycle pharmacy transactions with reversal as the final disposition

Numeric

Quarterly

Yes

V.

Medication Therapy Management Programs (MTMP)

The method used to enroll beneficiaries into the MTMP

Text

Semi-annually

Yes

Number of beneficiaries who met the eligibility criteria for the MTMP

Numeric

Semi-annually

Yes

Number of beneficiaries who participated in the MTMP

Numeric

Semi-annually

Yes

Number of beneficiaries who discontinued participation from the MTMP

Numeric

Semi-annually

Yes

Number of beneficiaries who discontinued participation from the MTMP due to death

Numeric

Semi-annually

Yes

Number of beneficiaries who discontinued participation from the MTMP due to disenrollment from the Plan

Numeric

Semi-annually

Yes

Number of beneficiaries who discontinued participation from the MTMP at their request

Numeric

Semi-annually

Yes

Number of beneficiaries who discontinued participation from the MTMP for a reason not specified in data elements E-G

Numeric

Semi-annually

Yes

Number of beneficiaries who declined to participate in the MTMP

Numeric

Semi-annually

Yes

Number of beneficiaries whose participation status in the MTMP is pending

Numeric

Semi-annually

Yes

Prescription cost of all medications for all beneficiaries participating in the MTMP (as of the last day of the reporting period specified) on a per MTMP beneficiary per month basis

Currency

Semi-annually

Yes

Number of covered Part D 30-day equivalent prescriptions on a per MTMP beneficiary per month basis

Numeric

Semi-annually

Yes

Data file containing various data fields for beneficiaries identified as being eligible for the Medication Therapy Management Program

Tab delimited text file

Annually

No

VI.

Generic Drug Utilization

Total number of paid claims for generic drugs

Numeric

Quarterly

Yes

Total number of paid claims

Numeric

Quarterly

Yes

VII.

Home Infusion Utilization

Number of Part D beneficiaries receiving Part D-covered home infusion drugs dispensed by any of its network providers as part of a bundled service under a Part C supplemental benefit (if applicable).

Numeric

Quarterly

Yes

The total claims associated with Part D-covered home infusion drugs dispensed by any of its network providers as part of a bundled service under a Part C supplemental benefit (if applicable).

Numeric

Quarterly

Yes

VIII.


Grievances


Number of fraud and abuse grievances received

Numeric

Quarterly

Yes

Number of enrollment/disenrollment grievances received

Numeric

Quarterly

Yes

Number of benefit package grievances received

Numeric

Quarterly

Yes

Number of pharmacy access/network grievances received

Numeric

Quarterly

Yes

Number of marketing grievances received

Numeric

Quarterly

Yes

Number of customer service grievances received

Numeric

Quarterly

Yes

Number of confidentiality/privacy grievances received

Numeric

Quarterly

Yes

Number of quality of care grievances received

Numeric

Quarterly

Yes

Number of exception grievances received

Numeric

Quarterly

Yes

Number of appeal grievances received

Numeric

Quarterly

Yes

Number of other grievances received

Numeric

Quarterly

Yes

Total number of grievances

Numeric

Quarterly

Yes

Total number of LIS grievances

Numeric

Quarterly

Yes

IX.

Pharmacy & Therapeutics Committees/ Provision of Part D Functions

Indicate if changes in P&T Committee membership.

Text

Quarterly

Yes

If changes, indicate if these are reflected within Contract Management module.

Text

Quarterly

Yes

Indicate if changes have occurred in organizations providing Part D functions.

Text

Quarterly

Yes

If changes, indicate if these are reflected within Contract Management module.

Text

Quarterly

Yes

X.

Transition


Minimum number of days supply the Plan’s transition policy provides for its one-time, temporary fill for enrollees in the retail setting.

Numeric

Quarterly

Yes

Minimum number of days, beginning on the enrollee’s effective date of coverage, in a plan’s transition process for enrollees in the retail setting

Numeric

Quarterly

Yes

Minimum number of days supply the Plan’s transition policy provides for its temporary fill (with multiple refills as necessary) for enrollees in the LTC setting.

Numeric

Quarterly

Yes

Minimum number of days, beginning on the enrollee’s effective date of coverage, in a plan’s transition process for enrollees in the LTC setting

Numeric

Quarterly

Yes

Minimum transition period has expired, the minimum number of days supply the Plan provides to LTC enrollees for an emergency supply of non-formulary Part D drugs while an exception is being processed

Numeric

Quarterly

Yes

Maximum number of business days after a temporary transition fill within which the Plan will send a written transition notice via U.S. first class mail

Numeric

Quarterly

Yes

XI.

Exceptions

Number of pharmacy transactions rejected due to failure to complete step edit requirements

Numeric

Quarterly

Yes

Number of pharmacy transactions rejected due to need for prior authorization (not including first pass step therapy edits or early refills)

Numeric

Quarterly

Yes

Number of pharmacy transactions rejected due to quantity limits in the time period specified above.

Numeric

Quarterly

Yes

Number of prior authorizations requested for formulary medications (not including first pass step therapy edits or early refills)

Numeric

Quarterly

Yes

Number of prior authorizations approved for formulary medications (not including first pass step therapy edits or early refills)

Numeric

Quarterly

Yes

Number of exceptions requested for non-formulary medications (not including early refills)

Numeric

Quarterly

Yes

Number of exceptions approved for non-formulary medications (not including early refills)

Numeric

Quarterly

Yes

Number of exceptions requested for tier exceptions (not including first pass step therapy edits or early refills)

Numeric

Quarterly

Yes

Number of exceptions approved for tier exceptions (not including first pass step therapy edits or early refills)

Numeric

Quarterly

Yes

Number of exceptions requested for quantity limits (not including early refills)

Numeric

Quarterly

Yes

Number of exceptions approved for quantity limits (not including early refills)

Numeric

Quarterly

Yes

XII.

Appeals





Number of appeals submitted for standard redetermination

Numeric

Quarterly

Yes

Number of appeals submitted for expedited redetermination

Numeric

Quarterly

Yes

Number of appeals submitted for expedited redetermination that were granted expedited status

Numeric

Quarterly

Yes

Number of appeals submitted for standard redetermination withdrawn by the enrollee

Numeric

Quarterly

Yes

Number of appeals submitted for expedited redetermination withdrawn by the enrollee

Numeric

Quarterly

Yes

Number of redeterminations resulting in full reversal of original decision

Numeric

Quarterly

Yes

Number of redeterminations resulting in partial reversal of original decision

Numeric

Quarterly

Yes

Number of adverse redeterminations due to insufficient evidence of medical necessity from enrollee’s prescribing physician

Numeric

Quarterly

Yes

Number of appeals submitted for IRE reconsideration due to inability to meet timeframe for coverage determination

Numeric

Quarterly

Yes

Number of appeals submitted for IRE reconsideration due to inability to meet timeframe for redetermination

Numeric

Quarterly

Yes

Number of IRE decisions for standard reconsideration resulting in full reversal of original coverage determination or redetermination

Numeric

Quarterly

Yes

Number of IRE decisions for standard reconsideration resulting in partial reversal of original coverage determination or redetermination

Numeric

Quarterly

Yes

Number of IRE decisions for expedited reconsideration resulting in full reversal of original coverage determination or redetermination

Numeric

Quarterly

Yes

Number of IRE decisions for expedited reconsideration resulting in partial reversal of original coverage determination or redetermination

Numeric

Quarterly

Yes

Number of IRE decisions for standard reconsideration resulting in upholding of original coverage determination or redetermination

Numeric

Quarterly

Yes

Number of IRE decisions for expedited reconsideration resulting in upholding of original coverage determination or redetermination

Numeric

Quarterly

Yes

XIII.

Overpayment

Total overpayment dollars identified to be recouped

Currency

Semi-Annually

Yes

Total overpayment dollars recouped

Currency

Semi-Annually

Yes

XIV.

Pharmaceutical Rebates, Discounts, and Other Price Concessions

REBATES_(SPONSORNAME)_(2008Q#).TXT

Tab delimited text file

Quarterly

Yes

DISCOUNTS_(SPONSORNAME)_(2008Q#).TXT

Tab delimited text file

Quarterly

Yes

XV.

Long-term Care (LTC) Rebates

REBATES_LTCPHARMACIES_(CONTRACT)_(2008Q#).TXT

Tab delimited text file

Quarterly

Yes

XVI.

Licensure and Solvency, Business Transactions and Financial Requirements







Licensed Part D PDP Contracts will submit Completed Health Blank form pages: Jurat, Assets, Liabilities, Capital and Surplus, Statement of Revenue and Expenses, Capital and Surplus Account, and Cash Flow
OR
Non-licensed Part D PDP Contracts will submit un-audited financial statements

Mailed to CMS

Quarterly

No

Documentation showing that an insolvency deposit of $100,000 is being held (for non-licensed Part D PDP Contracts and Direct Contract PDPs)

Mailed to CMS

Quarterly

No

Funding for projected losses worksheet (for non-licensed Part D PDP Contracts only)

Mailed to CMS

Quarterly

No

Independently audited financial statement with a management letter for Part D PDPs and Direct Contract PDPs

Mailed to CMS

Yearly (fiscal)

No

Copy of an Actuarial Opinion by a qualified actuary for the Part D PDP

Mailed to CMS

Yearly (fiscal)

No

Documentation on the status of obtaining licensure for each waived state (for Part D PDP Contracts with any state licensure waivers only)

Mailed to CMS

Quarterly

No

Documentation of significant business transactions

Mailed to CMS

Yearly (fiscal)

No

Un-audited financial statements for Direct Contract PDPs

Mailed to CMS

Quarterly

No

Copy of credit rating for Direct Contract PDPs

Mailed to CMS

Quarterly

No

ERISA Sec. 411(a) attestation for Direct Contract PDPs s

Mailed to CMS

Yearly


No

Total assets

Currency

Quarterly

Yes

Total liabilities

Currency

Quarterly

Yes

Total cash

Currency

Quarterly

Yes

Total cash equivalents

Currency

Quarterly

Yes

Total current assets

Currency

Quarterly

Yes

Total current liabilities

Currency

Quarterly

Yes

Total revenue

Currency

Quarterly

Yes

Total expenses

Currency

Quarterly

Yes

Total administrative expense

Currency

Quarterly

Yes

Total net income

Currency

Quarterly

Yes

Drug benefit expenses (excluding administrative expenses)

Currency

Quarterly

Yes

Drug benefit revenues

Currency

Quarterly

Yes

XVII.

Part D Benefit Analyses

Total number of non-LIS enrollees in the deductible phase

Numeric

Monthly

Yes

Total number of LIS enrollees in the deductible phase

Numeric

Monthly

Yes

Total number of non-LIS enrollees in the pre-initial coverage limit phase

Numeric

Monthly

Yes

Total number of LIS enrollees in the pre-initial coverage limit phase

Numeric

Monthly

Yes

Total number of non-LIS enrollees in the coverage gap

Numeric

Monthly

Yes

Total number of LIS enrollees in the coverage gap

Numeric

Monthly

Yes

Total number of non-LIS enrollees in the catastrophic coverage level

Numeric

Monthly

Yes

Total number of non-LIS enrollees in the catastrophic coverage level

Numeric

Monthly

Yes

Table 2: Changes made from CY 2007 Reporting Requirements



Reporting Requirements Section

Changes


Retail, Home Infusion, and Long-Term Care Pharmacy Access

This is a new section

Access to Extended Day Supplies at Retail Pharmacies

This is a new section

Vaccines

This is a new section

Reversals

This section can now be reported at the Part D Contract or Plan (PBP) level

Medication Therapy Management Programs

Data element revised:

  • In Element L revised equation to Days Supply/30

Data elements added:

  • Number of beneficiaries who discontinued participation from the MTMP for a reason not specified in data elements E-G

  • Number of beneficiaries whose participation status in the MTMP is pending

  • Data upload for beneficiaries identified as being eligible for the Medication Therapy Management Program

Generic Drug Utilization

The name of the section was changed from Generic Drug Rate.

Home Infusion Utilization

This is a new section

Grievances

Description added:

  • Added an example of enrollment/disenrollment issues or recognition of LIS eligibility problems.

Data element revised:

  • In element A added Plan Agent or broker in element

  • In element E added overly aggressive marketing in element

Data elements added:

  • Number of LIS grievances received related to Part D

Pharmacy & Therapeutics (P&T) Committees/Performance of Part D Functions

  • The name of this section was renamed to reflect incorporation of Performance of Part D Functions from subsection 4 of the Licensure & Solvency.

Description added:

Element A1. added during the time period specified above

Data elements revised:

A1-2, and B1-2 that drop-down box is no longer used.

Transition

Description revised:

  • New introduction paragraph

Data elements deleted:

  • Total number of beneficiaries who are in transition during the reporting time period

  • Number of prescriptions authorized during transition periods within the reporting time period

  • Number of enrollees receiving one or more prescriptions authorized during transition periods within the reporting time period

  • Number of days per transition period field.

Data elements added:

  • Minimum number of days supply the Plan’s transition policy provides for its one-time, temporary fill for enrollees in the retail setting

  • Minimum number of days, beginning on the enrollee’s effective date of coverage, in a plan’s transition process for enrollees in the retail setting.

  • Minimum number of days supply the Plan’s transition policy provides for its temporary fill (with multiple refills as necessary) for enrollees in the LTC setting

  • Minimum number of days, beginning on the enrollee’s effective date of coverage, in a plan’s transition process for enrollees in the LTC setting

  • Minimum transition period has expired, the minimum number of days supply the Plan provides to LTC enrollees for an emergency supply of non-formulary Part D drugs while an exception is being processed

  • Maximum number of business days after a temporary transition fill within which the Plan will send a written transition notice via U.S. first class mail

Exceptions


Data elements revised:

  • Elements D and E added quantity limits as an example

Appeals

Data element revised:

  • Element A added description (Do not include those appeals that were submitted as expedited, but were not granted expedited status.)


Call Center Measures: Beneficiary Service line and Pharmacy Support line


This section has been deleted

Overpayment


No changes made to this reporting section

Pharmaceutical Manufacturer Rebates, Discounts, and Other Price Concessions

No changes made to this reporting section

Long-term Care (LTC) Rebates

Data element revised:

  • In Section A, number 5. the description of Drug name has been revised to provide the brand name

Data elements added:

  • Addition of NDC - Provide the 11-digit NDC associated with this rebate

Licensure and Solvency, Business Transactions and Financial Requirements

Subsection 1: Financial and Solvency Requirements Documentation for Part D PDP Contracts;

Subsection 2:

Financial and Solvency Requirements Documentation for Direct Contract PDPs;

Subsection 3: Financial and Solvency Requirements HPMS Data elements for Part D PDPs and Direct Contract PDPs;

Subsection 4: Performance of Part D Activities HPMS Data elements for all Part D Contracts (including MA-PDs, PDPs, and Direct Contract PDPs)

Description revised:

Section description revised to include explanatory language about Direct Contract PDPs

Data elements revised:

Section I

  • Element D now reads: According to the quarterly time periods specified above, Part D PDP Sponsors not licensed in any state must submit documentation that demonstrates they possess the allowable sources of funding to cover projected losses for the greater of 7.5% of the aggregated projected target amount for a given year or resources to cover 100% of any projected losses in a given year. This documentation should include a worksheet indicating how they arrived at the aggregated projected target amount. Pro-forma financial statements including the balance sheet, income statement and statement of cash flows projecting through the next 12 months by quarter. Enrollment projections through the next 12 months by quarter. Guarantees, letters of credit and other documents essential to demonstrating that the funding for projected losses requirement has been met must also be included.

  • Element E added the sentence: Licensed entities may not report under GAAP for a period longer than 36 months.

  • Element G now reads: According to the quarterly time periods specified above, Part D PDP sponsors with any state licensure waivers must submit an update on the status of obtaining licensure for each waived state.

  • Element H reads: Per § 423.514 each Part D sponsor must report to CMS annually, within 120 days of the end of the fiscal year, significant business transactions, between the Part D sponsor and a party in interest.

Section II

  • Revised to note that All Direct Contract PDP Documentation should be mailed to the following found in the document

Section III

  • Section III header revised to Financial and Solvency Requirements data elements to be entered into HPMS – For Part D PDP Contracts / Direct Contract PDPs:

Section IV

  • This subsection moved to P&T Committee section.

Drug benefit analyses


  • Section to be reported monthly

Description revised:

Section overview includes an explanatory sentence, and revised re: how Plans with no coverage gaps or deductibles should report data.


Data elements added:

  • Number of non-LIS enrollees in the deductible phase as of the last day of the month.

  • Number of LIS enrollees in the deductible phase as of the last day of the month.

  • Number of LIS enrollees in the pre-initial coverage limit phase as of the last day of the month

  • Number of LIS enrollees in the coverage gap as of the last day of the month

  • Number of LIS enrollees in the catastrophic coverage level as of the last day of the month.







File Typeapplication/msword
File TitlePart D Plan Reporting Requirements
AuthorChristopher A. Powers
Last Modified ByCMS
File Modified2007-10-02
File Created2007-08-28

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