Supporting Statement - Part B CMS-10347

Agent Broker Training Requirements (CMS-10347)

Supporting Statement – Part B

Collections of Information Employing Statistical Methods

1 . Describe (including a numerical estimate) the potential respondent universe and any sam­pling or other respondent selection method to be used. Data on the number of entities (e.g., establishments, State and local government units, households, or persons) in the universe covered by the collection and in the corre­sponding sample are to be provided in tabular form for the universe as a whole and for each of the strata in the proposed sample. Indicate expected response rates for the collection as a whole. If the collection had been conducted previously, include the actual response rate achieved during the last collection.

• This is a new collection and we estimate that about 12 entities (plan sponsors and/or third party vendors) will submit a proposal annually and that the average estimated hours per entity to complete the proposal is 100 hours. The total estimated hourly burden associated with this requirement is equal to the estimated number of entities (12) x the estimated hours per entity (100) = 1,200 hours. We estimate the hourly labor cost for the preparer of the proposal will be $59.20 (based on the U.S. Department of Labor statistics for hourly wages for management analysts). The annual cost of proposal preparation is estimated to be $71,040 ($59.20 x 1200 hours).

2. Describe the procedures for the collection of information including:

- Statistical methodology for stratification and sample selection,

- Estimation procedure,

- Degree of accuracy needed for the pur­pose described in the justification,

- Unusual problems requiring specialized sampling procedures, and

- Any use of periodic (less frequent than annual) data collection cycles to reduce burden.

• Upon finalizing the rule that agents and brokers receive their annual Medicare training through a CMS endorsed or approved training program, we are considering implementing the requirement through a request for proposal (RFP) competitive process. However, we are seeking comments and suggestions about alternatives to using the RFP competitive process in the proposed rule set to be published tentatively on September 7, 2010.

• For the RFP process, a package is prepared by the Office of Acquisitions and Grant Management (OAGM) and issued in order to request a technical and business proposal in response to CMS requirements. This document prepared includes: Statement of Work, Schedule of Deliverables, Terms and Conditions, Evaluation Criteria, and Other Supporting Documentation.

3. Describe methods to maximize response rates and to deal with issues of non-response. The accuracy and reliability of information collected must be shown to be adequate for intended uses. For collections based on sam­pling, a special justification must be provid­ed for any collection that will not yield 'reliable' data that can be generalized to the uni­verse studied.

• Not applicable; the RFP process is voluntary and open to all health plan sponsors and third party entities to compete.

4. Describe any tests of procedures or methods to be undertaken. Testing is encouraged as an effective means of refining collections of information to minimize burden and improve utility. Tests must be approved if they call for answers to identical questions from 10 or more respondents. A proposed test or set of tests may be submitted for approval separate­ly or in combination with the main collection of information.

• As discussed above, we are seeking alternatives to the RFP process. We will determine which process to use for implementing our requirement once we have reviewed public comment and finalized the rule. If feedback received from the public suggests that the RFP process is best for implementing the requirement, we would work with OAGM to prepare the RFP package discussed above.

5. Provide the name and telephone number of individuals consulted on statistical aspects of the design and the name of the agency unit, contractor(s), grantee(s), or other person(s) who will actually collect and/or analyze the information for the agency.

• Camille Brown, CMS, 410-786-0274

• Vanessa Duran, CMS, 410-786-8697

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