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| Comment Number |
Entity Submitting Comments |
Subject Matter |
Summary of Comment |
Accept/Deny Change |
| Clarification Comments (comments not on substantive information within the application; CMS will clarify directly with commenters) |
| 1 |
CMS |
Benefit Design |
Change an attestation to reflect that applicants will need to upload transition policies through HPMS instead of the formulary website. |
Accept |
| 2 |
Humana, United Health Group/Ovations, Aetna |
Instruction and Format of Qualifications - Calendar |
The instruction section of the solicitation states that CMS will check the application for completeness shortly after receipt. CMS will notify Applicants of any deficiencies and afford them a courtesy opportunity to amend their applications. This period to correct deficiencies is not listed in the calendar. Commenters recommend that Part D follow the same calendar as Part C. |
Accept with clarification. Part D will include the dates for the courtesy cure period with the notation that dates are subject to change. |
| 3 |
Humana |
Applicant Experience, Contracts, Licensure and Financial Stability |
Application asks for the sample copy of each provider contract and corresponding matrix. Many of our provider contracts apply nationwide. We recommend that either we enter the sample contracts once and have the ability to copy over the provider contracts to each of the applications it applies to or a drop down box (similar to the Marketing module) where we designate what contracts these provider contracts apply to. This will help reduce the possibility of error because we do not have to submit the same contracts multiple times under different file names. Additionally this will also assist CMS in the review of the application. CMS will not have to look at the same contracts multiple times. |
Deny. The Part D application only requests executed contracts for first tier, downstream or related entities that are performing key Part D functions. The Part D application does request templates of pharmacy network contracts and does not request provider contracts at all. This comment seems to be more in reference to the Part C applications. |
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