2014 High Levels Summary of Changes 9-17-12(30-day)(Final Draft)

2014 High Levels Summary of Changes 9-17-12(30-day)(Final Draft) .pdf

Medicare Advantage Application - Part C and 1876 Cost Plan Expansion Application regulations under 42 CFR 422 subpart K & 417.400

2014 High Levels Summary of Changes 9-17-12(30-day)(Final Draft)

OMB: 0938-0935

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High-Level Summary of Changes to the Part C Application for the 2014 Application Season
(30-day comment period)

Revision

Purpose of the Revision

2013 Part C
Application

Application
Section

Category
of
Comment

Level of
Applicant
Burden
I=
Increases
burden
D–
Decreases
burden
N – No
Change

GENERAL INFORMATION AND INSTRUCTIONS
1. High level edits to entire document including the
addition of missing words, capitalization,
deletion of missing spaces, and renumbering

To maintain a consistent format

Entire Document

All Sections

N/A

N

2. Corrected addresses for Boston, Dallas and
Seattle Regional Offices
3. Added clarification on partial county
submissions to clarify that CMS will not accept
partial county requests after the initial
application submission

Correction

Section 1

N/A

N

Clarification

Section 2

1.4 – Technical
Support
2.6 – Applicants
Seeking to Serve
Partial Counties

N/A

N

To comply with CMS requirements and
acknowledge that CMS does not specify
“key personnel.”
To provide detailed information to clarify
the current process for submitting proof
of renewal.

Section 3 Attestations

3.1 – Experience and
Organization History

N/A

D

Section 3 Attestations

3.3 – State Licensure

N/A

N

ATTESTATIONS
4. Delete the request for key personnel resumes.

5. Revise the attestation language under the “State
Licensure” section to explain the process for
submitting renewed license documentation. The
attestation reads: “…Applicant agrees to upload
into HPMS the renewed license no later than the
final upload. If the renewed license is not
available at that time. Applicant agrees to (1)
upload, in place of the license, a copy of its
completed license renewal application or other
documentation (e.g., invoice from payment of
renewal fee) to show that the renewal process is
being completed in a timely manner, and (2)

1

High-Level Summary of Changes to the Part C Application for the 2014 Application Season
(30-day comment period)

Revision

Purpose of the Revision

2013 Part C
Application

Application
Section

Category
of
Comment

Level of
Applicant
Burden
I=
Increases
burden
D–
Decreases
burden
N – No
Change

electronically send a copy of the renewed
license to the CMS Regional Office Account
Manager promptly upon issuance.
6. Revise language in Section B and C to read: “If
you are applying as an MA-only non-network
organization (i.e., PFFS or MSA), in HPMS…”
7. Revise attestation #1 to read, “Applicant attests
that all staff is qualified to perform their
respective duties.” “…as outlined in the key
management position descriptions outlined in
Section B” was removed from the original
sentence.
8. Revised attestation #2 to clarify the location of
the required chart.

To clarify and make current text
consistent.

Section 3 Attestations

3.5 Compliance Plan

N/A

N

To be consistent with no longer
requesting position descriptions.

Section 3 –
Attestations

3.6 – Key
Management Staff

N/A

N

Clarification

Section 3 –
Attestations

3.6 – Key
Management Staff

N/A

N

9. Delete Section “B” request for uploaded PDs.

To comply with CMS requirements and
acknowledge that CMS does not specify
“key personnel.”
To reduce repetitive language found in
the State Licensure section.
To clarify confusion among applicants
during the CY 2013 MA application
season and ensure that full county to
partial county changes are not made in
the middle of the application review
process.

Section 3 –
Attestations

3.6 – Key
Management Staff

N/A

D

Section 3 Attestations
Section 3 –
Attestations

3.7 – Fiscal
Soundness
3.8 – Service Area

N/A/60-day

N

N/A

N

10. Delete Sections 3.7A.2, 3.7A.3, and 3.7C.
11. Add a note between sections “A” and “B” to read
the “Applicant may only designate or request a
partial county service area during the initial
application submission.
Also added “…and Partial County Network
Assessment Table” to the end of the sentence in

2

High-Level Summary of Changes to the Part C Application for the 2014 Application Season
(30-day comment period)

Revision

Purpose of the Revision

2013 Part C
Application

Category
of
Comment

Level of
Applicant
Burden
I=
Increases
burden
D–
Decreases
burden
N – No
Change

3.9 – CMS Provider
Participation
Contracts &
Agreements
(attestation #2)
3.9 – CMS Provider
Participation
Contracts &
Agreements
(attestations #5-7)

N/A

N

N/A

N

3.9 – CMS Provider
Participation
Contracts &
Agreements
3.9 – CMS Provider
Participation
Contracts &
Agreements

N/A

N

N/A

N

3.10 – Contracts for
Admin. &
Management
Services

N/A

N

Application
Section

Section 3.8 B.
12. Revise attestation #2 to update the name of the
matrix to CMS Provider Contract Required
Provisions Matrix.

To make the matrix title consistent
throughout the application.

Section 3 –
Attestations

13. Add the CMS Model MA Contract Addendum
attestations back into this section upon OGC
approval. Edited to remove the word “Model”
from CMS Model Medicare Advantage Contract
Amendment because the name of the document
submitted to OGC does not include the word
“Model”.
14. Added NOTE following the attestations to clarify
what the CMS Medicare Advantage Contract
Amendment is and when it was/will be released
(pending date).
15. Revise instructions in Section B to read, “In
HPMS, upon request, upload a completed "CMS
Contract Sample Matrix," the "CMS Provider
Contract Required Provisions Matrix," and the
provider contracts that CMS will name during
the application review process...”
16. Delete attestations #2-13 and add language in
new #2 attestation asking the applicant to verify
that the information it has provided in the HPMS
Delegated Business Function Table accurately

To support the lean process
improvement by reviewing a smaller
sample of actual vs. the entire universe
of the template contracts. To maintain
consistency within the application
document.

Section 3 –
Attestations

Clarification

Section 3 –
Attestations

To support the lean process
improvement by including the CMS
Provider Contract Required Provisions
Matrix.

Section 3 –
Attestations

To streamline the MA application and
consolidate attestations.

Section 3 Attestations

3

High-Level Summary of Changes to the Part C Application for the 2014 Application Season
(30-day comment period)

Revision

describes/names its delegated entities and
functions.
17. Delete the reference to applicant’s parent
organization.

Purpose of the Revision

2013 Part C
Application

To eliminate confusion and provide
clarity.

Section 3 –
Attestations

18. Revised attestation #5 to clarify that CMS is
seeking information about whether the applicant
received an application approval during one of
the last two review cycles, not on whether or not
CMS approved the applicant’s administrative
agreements during those application reviews.
19. Revise the name of the CMS Administrative
Contract/Management Delegated Contracting
Matrix to CMS Administrative Contract Required
Provision Matrix.

Clarification of requested information in
attestation.

Section 3 –
Attestations

To ensure that the name of the Matrix is
consistent throughout the application.

Section 3 –
Attestations

20. Revise current language to read: "…If the
Applicant has received a Part C application
approval, initial or SAE, from CMS during one or
both of the two most recent application review
cycles (refer to Attestation #15), then no
administrative contract upload is necessary."
21. Delete Section A.

To clarify the current text.

Section 3 –
Attestations

To reduce duplication. Section A does
not serve a purpose since uploads are
requested in Section B.

Section 3 –
Attestations

4

Category
of
Comment

Level of
Applicant
Burden
I=
Increases
burden
D–
Decreases
burden
N – No
Change

3.10 – Contracts for
Admin. &
Management
Services (attestation
#4); 3.10D
3.10A – Contracts for
Admin &
Management
Services (attestation
#5)

N/A

N

N/A

D

3.10A – Contracts for
Admin. &
Management
Services (attestation
#4); 3.10 C.; 4.5
Matrix
3.10D – Contracts for
Admin. &
Management
Services

N/A

N

N/A

N

3.22 Part C
Application
Certification

N/A

N

Application
Section

High-Level Summary of Changes to the Part C Application for the 2014 Application Season
(30-day comment period)

Section 3 –
Attestations

3.24A – Access to
Services (PFFS &
MSA)

N/A

Level of
Applicant
Burden
I=
Increases
burden
D–
Decreases
burden
N – No
Change
N

Section 3 –
Attestations

3.28 – Tiering of
Medical Benefits

N/A

D

To combine the two specialties into
Cardiothoracic Surgery.

N/A

N/A

N/A

N

25. Revise the section name to match the new
matrix name: “CMS Provider Contract Required
Provision Matrix.”

To provide consistency throughout the
application.

Section 4 Templates

4.3 - CMS Provider
Contract Matrix

N/A

N

26. Revise the Instructions: Instructions for CMS
Provider Contract Required Provision Matrix.
This matrix must be completed… that CMS has
identified in the contract sample and in those
contracts that link the identified provider / facility
to the Applicant.
27. Revise Matrix instructions Step 2. “At the top of
each column, enter the name of the provider…”

To clarify requested sample.

Section 4 Templates

4.3 - CMS Provider
Contract Matrix
(instructions)

N/A

N

To provide clarification to the applicant.

Section 4 Templates

4.3 - CMS Provider
Contract Matrix (Step
#2)

N/A

N

Revision

Purpose of the Revision

22. Added note of clarification following attestations
that a PFFS applicant cannot select multiple
model types (attestations #1-3) for a single
application.

Clarification – An applicant submitted a
CY2013 application selecting both
network-only and combination models,
which was not appropriate but not
recognized as a deficiency by CMS until
late in the review process.
CMS will collect this information outside
the application process.

23. Delete Section 3.28 “Tiering of Medical
Benefits.”

2013 Part C
Application

Application
Section

Category
of
Comment

HSD INSTRUCTIONS, TABLES AND EXCEPTION PROCESS
24. Instructions updated to reflect the removal of
Cardiac Surgery and Thoracic Surgery.

TEMPLATES

5

High-Level Summary of Changes to the Part C Application for the 2014 Application Season
(30-day comment period)

28. Revised Matrix instructions Step 3 to remove
“Model” from CMS Model Medicare Advantage
Contract Amendment to match the document
name.
29. Revise Matrix instructions Step 5. Designate
downstream provider(s), group(s) or other entity
with a "(DS)" next to the provider / facility name.

To provide clarification to the applicant.

Section 4 Templates

4.3 - CMS Provider
Contract Matrix (Step
#3)

N/A

Level of
Applicant
Burden
I=
Increases
burden
D–
Decreases
burden
N – No
Change
N

To provide clarification to the applicant.

Section 4 Templates

4.3 - CMS Provider
Contract Matrix (Step
#5)

N/A

N

30. Revise Matrix instructions Step 6 to clarify
where the information is appropriate.

To provide clarification to the applicant.

Section 4 Templates

4.3 - CMS Provider
Contract Matrix (Step
#6)

N/A

N

31. Revised the CMS Provider Contract Required
Provision Matrix to include two new rows (to
repeat at the top of each page) showing whether
the applicant has used the CMS Medicare
Advantage Contract Amendment and if the
provider listed is first tier or downstream.
Neither are new matrix requirements, but they
were previously combined with the provider
name cell.
32. Revise the CMS Provider Contract Required
Provision Matrix second regulation (CFR
422.504 (a) 13 and 422.118) title from
Confidentiality and Enrollee Record Accuracy to
Confidentiality L/W CMS and Sponsor

To provide clarification to the applicant

Section 4 –
Templates

4.3 – CMS Provider
Contract Matrix

N/A

N

To provide clarification to the applicant.

Section 4 Templates

4.3 - CMS Provider
Contract Matrix (CFR
422.504 (a) 13 and
422.118)

N/A

N

Revision

Purpose of the Revision

6

2013 Part C
Application

Application
Section

Category
of
Comment

High-Level Summary of Changes to the Part C Application for the 2014 Application Season
(30-day comment period)

33. Revise Delegated Activities and list them
individually.

To provide clarification to the applicant
and the CMS reviewers.

Section 4 Templates

4.3 - CMS Provider
Contract Matrix
(Delegated Activities)

N/A

Level of
Applicant
Burden
I=
Increases
burden
D–
Decreases
burden
N – No
Change
N

34. Revise the instructions to include the new matrix
name: Instructions: The Applicant must…The
applicant must also submit a completed CMS
Provider Contract Required Provision Matrix
indicating…
35. Add language back into the sample matrix:
…”Indicate with an “M” any contracts that use
the CMS Model Medicare Advantage Contract
Amendment.”
36. Changed the heading in column 3 from “If
different from column B…” to “If different from
Provider Name…” because we don’t have
column letter headings and referring to a
Column B might confuse applicants.
37. Changed heading of column 5 by deleting
reference to Column A (which actually conflicted
with the previous reference to that same column
as Column B) and removing “Model” from the
CMS Model Medicare Advantage Contract
Amendment.
38. Revise matrix name: CMS Administrative
Contract Required Provision Matrix

To maintain consistency throughout the
MA application.

Section 4 Templates

4.4 - CMS Contract
Sample Matrix
(instructions)

N/A

N

Lean process improvement Model
Contract Amendment.

Section 4 Templates

4.4 - CMS Contract
Sample Matrix
(column #5)

N/A

N

To provide clarification to the applicant.

Section 4 Templates

4.4 - CMS Contract
Sample Matrix
(column #3)

N/A

N

Clarification and to ensure consistency

Section 4 Templates

4.4 - CMS Contract
Sample Matrix
(column #5)

N/A

N

To ensure consistency throughout the
entire application

Section 4 Templates

4.5 CMS
Administrative /
Management
Delegated

N/A

N

Revision

Purpose of the Revision

7

2013 Part C
Application

Application
Section

Category
of
Comment

High-Level Summary of Changes to the Part C Application for the 2014 Application Season
(30-day comment period)

Revision

Purpose of the Revision

2013 Part C
Application

Category
of
Comment

Level of
Applicant
Burden
I=
Increases
burden
D–
Decreases
burden
N – No
Change

4.5 CMS
Administrative /
Management
Delegated
Contracting Matrix
4.5 CMS
Administrative /
Management
Delegated
Contracting Matrix
(Step 3)
4.5 CMS
Administrative /
Management
Delegated
Contracting Matrix
4.13 Tiering of
Medical Benefits
Request Document

N/A

N

N/A

N

N/A

N

N/A

D

4.13 - Partial County
Justification

N/A

N

Application
Section

Contracting Matrix

39. Revised Matrix instructions to keep format
consistent with previous matrix instructions.

To ensure consistency throughout the
entire application

Section 4 Templates

40. Inserted new step #3 to include instructions on
marking if the administrative contract /
agreement used the CMS Medicare Advantage
Contract Amendment

To ensure consistency throughout the
entire application

Section 4 Templates

41. Revised CMS Administrative Contracting
Required Provision Matrix to include a new
header row requesting information about
whether the administrative contract includes the
CMS Medicare Advantage Contract Amendment
42. Remove Section 4.13: Tiering of Medical
Benefits Request Document

To ensure consistency throughout the
entire application

Section 4 Templates

To coincide with the policy decision on
pages 86-88.

Section 4 Templates

43. Insert Partial County Justification document as
the new Section 4.13. Revised document
attached.

To address the 2014 requirement.

Section 4 Templates

8

High-Level Summary of Changes to the Part C Application for the 2014 Application Season
(30-day comment period)

To address the 2014 requirement.

Section 4 Templates

4.14 - Partial County
Network Assessment
Table

N/A

Level of
Applicant
Burden
I=
Increases
burden
D–
Decreases
burden
N – No
Change
N

45. Insert the revised D-SNP State Medicaid
Agency Contract Upload Document to reflect
what is currently present in HPMS.

To be consistent with the online
application.

14. - D-SNP Upload
Document (Number
3)

60-day

N

46. Revised the question #1 to read “If no, go to
question #4” instead of question #3. The note
was also updated to refer to question #4.

To correct an error in the application.

6. - D-SNP Medicaid

N/A

N

47. Revise the name of the former D-SNP State
Medicaid Agency Contract Upload Document to
the D-SNP State Medicaid Agency Contract
Negotiation Status Document.

To reduce confusion among applicants.

APPENDIX I:
Solicitations for
Special Needs
Plan (SNP)
Proposals
APPENDIX I:
Solicitations for
Special Needs
Plan (SNP)
Proposals
APPENDIX I:
Solicitations for
Special Needs
Plan (SNP)
Proposals

14. - D-SNP Upload
Document (Number
3)

N/A

N

APPENDIX II:
Employer/Union
-Only Group
Waiver Plans

6.4 Attestations (2.
Certification; #9)

60-day

N

Revision

44. Insert Partial County Network Assessment
Table as new Section 4.14. Revised document
attached.

Purpose of the Revision

2013 Part C
Application

Application
Section

Category
of
Comment

Special Needs Plan (SNP) Proposals

Agency(ies)
Contract(s),

Employer/Union Direct Contract for MA
48. Revise the CFR references in #9 from 42 CFR
422.80 and 42 CFR 423.80 to 42 CFR 422.2262
to 42 CFR 423.2262.

To be accurate with 42 CFR.

9

High-Level Summary of Changes to the Part C Application for the 2014 Application Season
(30-day comment period)

Revision

Purpose of the Revision

2013 Part C
Application

(EGWPs) MAO
“800 Series”

10

Application
Section

Category
of
Comment

Level of
Applicant
Burden
I=
Increases
burden
D–
Decreases
burden
N – No
Change


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File TitleRevision
AuthorCMS
File Modified2012-09-17
File Created2012-09-17

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