Response to public comments

Response to Public Comments

OMB # 0938 - 0944

CMS-10142

Bid Pricing Tool (BPT) for Medicare Advantage and Prescription Drug Plans

Health Net, December 21, 2007 letter

BPT Tool

1. Optional Supplemental Worksheet 7: please add a place to describe each benefit, cost sharing and any maximums.

Response: Optional Supplemental Worksheet 7 provides 1000 characters to describe each benefit category. If more space is need, a detailed description may be uploaded in supporting documentation. We believe that this is more efficient than expanding the size of the 100 benefit categories (20 for each of the five optional supplemental packages) or adding 100 or more fields for additional information that would be used by a relatively small number of plans.

2. Part D only BPT cost sharing, please add a place to describe the cost sharing by tier and any maximums, etc.

Response: This information is contained in the PBP submitted with the BPT.

AHIP, December 21, 2007 letter

MA

Response: Worksheet 3 contains subcategories for most service categories in order to provide flexibility in classifying cost sharing. For example, cost sharing for the professional component of a vision benefit may be reflected in the professional category or in the vision category. Subcategories are also used for variation in types of cost sharing within a service category such as coinsurance and co pays. Further, plans may define additional subcategories need for their plan design. However, this level of detail would result in a relatively small pmpm cost in many cases that is not necessary or significant for pricing purposes. It would increase the size of Worksheets 1, 2 and 4 and the work needed for plan sponsors to map costs from the various classifications in their internal pricing systems to the service categories in the BPT. Therefore, we decided not to expand the service categories on Worksheets 1 and 2. Plan sponsors may upload supporting documentation to clarify their classification of cost sharing and the relationship to the service categories on Worksheets 1 and 2.

PD

Response: The source of the data for completion of base period experience in Worksheet 1 needs to be the PDE, because this is the source of the data used in the reconciliation. To split out items like generic use on Worksheet 2 it is appropriate to rely upon additional sources of data. This data however, must tie to the PDE data unless the PDEs do not appropriately capture the plan’s expected experience.

Response: This information is contained in the PBP submitted with the BPT.

Response: Credibility guidelines for Part D are being considered for the BPT instructions for CY 2009.

Ovations, December 21, 2007 letter

Response: CMS’ policy regarding the gain/loss changes permitted during rebate reallocation has not changed since the first year of the bidding process. Plans have the ability to change member premiums and/or benefits during rebate reallocation. As an additional option, they can make minor changes to the gain/loss margin assumption. Generally, changes to the actuarial bid assumptions are not permitted, but plans are afforded the opportunity to slightly revise the gain/loss margin assumption.

Response: The allocation of SG&A and gain/loss margin proportionately between Medicare Covered and A/B Mandatory Supplemental Benefits applies to rebate allocation as well as the initial bid development.

Response: This comment does not affect the CY2009 Bid Pricing Tools or instructions but will be considered this summer prior to the release of the Part D National Average and Regional PPO benchmarks in early August.

Response: We expect to release a beta test version of the CY2009 Bid Pricing Tools in early 2008.

Response: The draft CY2009 bid instructions were revised to list major changes from CY2008. Our goal is to release all bid related guidance no later than in early April, if at all possible.

Response: Worksheet 2 is a summary of projected allowed costs. Detailed information about the calculations can be uploaded as supporting documentation, which does not require a revision to the BPT.

CMS is exploring ways in which to improve validation that the correct versions of the BPT and PBP are being submitted.  This comment does not impact the BPTs or the bid instructions.  

Response: A bid submission generally includes a PBP, and a MA and/or Part D BPT. It is not possible to upload an incomplete bid submission or make edits to a previously submitted bid. If a resubmission is required, both the PBP and required BPTs need to be submitted.

Response: Technical improvements in the forms have minimized the need for additional versions of the BPT.

Response:  Technical issues related to the bid submission should be provided to the HPMS Help Desk.

Response: The interaction between utilization and price changes may be accounted for as “other” changes for purposes of completing Worksheet 2.

Response: The credibility factors are applied to the total cost. The credibility factors may be adjusted slightly to tie out to the exact projected cost.

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