Crosswalk

Crosswalk—Medicare Part C and Part D Data Validation 2015-2017—10305 OCN 0938-1115—
Response to 60-Day Comments

First Version/60-Day
Comment
The supporting documents
for CMS-10305 were never
made available.

Change/New Version

RSC for Data Element 6.1
indicates that the
organization should
accurately calculate the
number of fully favorable
organization determinations.
The phrase “fully favorable”
appears inconsistent with
Data Element 6.1 of the Part
C Technical Specifications,
which requires the reporting
of the “total number of
organization determinations
made in [the applicable]
reporting time period.”

CMS reviewed and revised the
language in the Standards
(Appendix A) to conform to the
Data Element 6.1 language in the
Part C Technical Specifications.

CMS made the supporting
documents available at:
http://www.cms.gov/Regulations
-andGuidance/Legislation/Paperwork
ReductionActof1995/PRA-ListingItems/CMS10305.html?DLPage=1&DLFilter=
CMS10305&DLSort=1&DLSortDir=des
cending

Reason for
Change
Based on
public
comment

Burden
Change
No

Based on
public
comment.

No

First Version/60-Day
Comment
Lack of alignment of
terminology. There were
several places in Appendix 1
where the terminology had to
be revised.

Change/New Version

Item #13 under the RSC of
Section 2.7 for Appendix 1
indicates that for data
Element 1.N the organization
accurately calculates “the
number of coverage
determinations decisions
processed timely.” However,
Note 14 in the corresponding
Part D Technical
Specifications stated that
certain untimely cases should
also be included in Data
Element 1.N (refer to Note
14, page 62). Note 14
appears to conflict with the
Data Validation Standard
described in Item #13.

CMS updated the 2014 Part D
Technical Specifications to clarify
Note 14 for the Coverage
Determinations and
Redeterminations reporting
section. Untimely cases should
not be included in Data Element
1.N.

In Appendix 1, CMS replaced the
term “measure” with “reporting
section” and the term “measurespecific criteria” with “reporting
section criteria.”

Reason for
Change
Based on
public
comment.

Burden
Change
No

Based on
public
comment.

No

First Version/60-Day
Comment
The table of contents in the
Data Validation Standards
document (Appendix 1) did
not align with the section
numbers noted throughout
the document.

Change/New Version

Reason for
Change
CMS made the necessary
Based on
alignment of the section numbers public
in the Data Validation Standards
comment.
document (Appendix1).

Burden
Change
No

The old Findings Data
Collection Form (Appendix 5),
which is used as the main
model for recording data
validation data in HPMS, did
not allow DVAs to record
separate findings for many
single data elements.
Previously, the findings
pertained to aggregates of
data elements that were not
as effective in informing
sponsors of specific problems
with individual data
elements.

CMS revised the FDCF (Appendix
5) so that the individual data
elements will be separately
scored.

Based on
internal
review.

No

For data element 2.A, the
Technical Specifications and
DV Standard 16i are
inconsistent with DV
Standard 19c. Data Element
2.A and DV Standard and 16i
state that dismissals and
withdrawals should not be
included in Data Element 2.A;
however, DV Standard 19c
states that they should be
included.

The Technical Specifications and
RSC 16i are correct in that
dismissals and withdrawals are
not included in element 2.A. RSC
19c was revised to state: Each
number of calculated requests
for redeterminations that were
withdrawn (Data Element 2.F)
and requests for
redeterminations that were
dismissed (Data Element 2.G) is
not to be included in the number
of redeterminations decisions
made (Data Element 2.A).

Based on
public
comment.

No

Appendix 4 states “Each Part
C and Part D reporting
section’s FDCF is included in a
corresponding worksheet
within the overall FDCF
Microsoft Excel file.”

This sentence was removed,
because FDCF is now a word
document.

Based on
internal
review.

No