CMS-10321.Justification of Nonsubstantive Change

0938-1087

HHS Form CMS-10321

Summary of Changes Associated with Change Worksheet.

Enclosed are markups indicating how HHS would like to change the Application portion of the aforementioned approved PRA package, and the corresponding Application Instructions portion of that PRA package. We respectfully request that OMB approve the changes. We don’t believe the changes add to burden.

Many of the changes were made to account for the fact that the initial application will be a paper application, while the PRA submission envisioned an online application. Also, Item 8 in the Plan Sponsor Agreement was added to compensate for an oversight on our part when the PRA package was submitted. Most of the rest of the changes are either stylistic in nature, or are intended to better flesh out the information we are requesting.

Please be aware that the added attachment at the end of the Application is not a new form, but rather republishes Part II, section B of the application. The version of the Application approved by OMB required the plan sponsor to furnish the information in Part II, section B, for each benefit option in the Application. The Attachment essentially republishes that section of the Application for the convenience of plan sponsors that have multiple plan options.