Crosswalk

2017 High Level Summary of Change or Crosswalk of Changes for
PRA Package CMS 10237: Part C - MA and 1876 Cost Plan Expansion Application

Revision/Clarification

Purpose of the
Revision/Clarification

2017 Part C
Application

Application
Section

TECHNICAL
CHANGES
1. Edits to MA Part C & 1876 Cost
To maintain a consistent format
and MA Part C &
All Sections
Plan Expansion Application, HSD
provide accurate timeframes
1876 Cost Plan
Instructions , MA Provider and
and instructions.
Expansion
Facility HSD Tables and Exception
Application,
Request Template including
HSD
the addition of missing words,
Instructions, MA
clarifying language, capitalization,
Provider and
deletion of missing spaces, grammar
Facility HSD
and final dates.
Tables, and
Exception
Request
Template

Level of
Applicant
Burden I =
Increases
Category of burden
Comment D –
Decreases
burden
N – No
Change
N/A

N

60 Day

I

SUBSTANTIVE CHANGES
1. Service Area Expansion (SAE)
applications will require HSD
Tables for the entire MAO
network not just the counties the
plan is proposing to expand into
with the SAE request.

Provides support and focus to CMS
commitment to monitoring network
adequacy for MA.

1

2.7 Type of
Applications

SAE Applications
are for:

2017 High Level Summary of Change or Crosswalk of Changes for
PRA Package CMS 10237: Part C - MA and 1876 Cost Plan Expansion Application

Revision/Clarification

2. Revised attestation #1 to Section
3.2 of the application. A contract
of the applicant has been nonrenewed or termination within the
past 2 years. If the Applicant
attests “yes” the organization
must submit the Two Year
Prohibition Waiver Request
upload document for CMS
review.

3. Added Two Year Prohibition
Waiver Request Upload
Document.

Purpose of the
Revision/Clarification

2017 Part C
Application

This attestation was revised to
provide the applicant instructions
on how to proceed with waiver
request related to the Two Year
Prohibition as set forth in 42 CFR
422.506(a)(4)(a). CMS will not
enter into a contract with a
Medicare Advantage Organization
for 2 years unless there are special
circumstances that warrant special
consideration as determined by
CMS.
The Two Year Prohibition Waiver
Request Upload Document is being
provided to applicants to request
consideration by CMS of the special
circumstance related to non-renewal
and/or termination of MAO contract
within the past 2 years.

2

Application
Section

Section 3
Attestations

3.2 Administrative
Management

Section 4
Document
Upload
Templates

4.3 Two Year
Prohibition Waiver
Request Upload
Document

Level of
Applicant
Burden I =
Increases
Category of burden
Comment D –
Decreases
burden
N – No
Change
60-day
N

60-day

I

2017 High Level Summary of Change or Crosswalk of Changes for
PRA Package CMS 10237: Part C - MA and 1876 Cost Plan Expansion Application

Revision/Clarification

Purpose of the
Revision/Clarification

2017 Part C
Application

Application
Section

4. Revised language in section on
Fiscal Soundness to clarify the
information the applicant should
upload via HPMS for CMS to
review.

CMS clarified the information the
applicant should submit for review
of Fiscal Soundness of a MAO.

Section 3
Attestations

5. Deleted attestation # 7 in the
Health Services Management &
Delivery section. Applicant
agrees that all “applicable “
contracted physicians /providers
listed in the Provider Table have
admitting privileges , as
appropriate ,(other than courtesy
privileges) at contracted facility.

The attestation was deleted because
CMS does not have requirement
related to “admitting privileges”.
Reduce applicant confusion related
to “applicable “contracted
physicians/providers and admitting
privileges.

Section 3
Attestations &
Appendix IVMedicare Cost
Plan SAE

3.11 Health Services 60-day
Management &
Delivery and 8.5
Health Services
Management &
Delivery

D

6. Delete requirement for upload
documents in the Quality
Improvement Program
attestation section. Applicant
will no longer be required to
upload the QI Program Matrix
and Crosswalk for Part C QI
Program.

The upload requirements were
removed from Section 3.12 Quality
Improvement Program and replaced
with 18 attestation questions.

Section 3
Attestations

3.12 Quality
Improvement
Program

60-day

D

3

3.7 Fiscal Soundness

Level of
Applicant
Burden I =
Increases
Category of burden
Comment D –
Decreases
burden
N – No
Change
60-day
N

2017 High Level Summary of Change or Crosswalk of Changes for
PRA Package CMS 10237: Part C - MA and 1876 Cost Plan Expansion Application

Revision/Clarification

7. Added question#5 to Minimum
Enrollment Waiver Request Upload
Document as follows: Please
describe any factors, such as specific
populations your organization
intends to serve or geographic
locations, which may result in low
enrollment?
8. Deleted two requirements under the
Partial County Justification Upload
document related to the criteria of
Necessary. The applicant will be
required to describe the evidence to
substantiate the criteria.

Purpose of the
Revision/Clarification

2017 Part C
Application

Application
Section

CMS is requesting clarification
from the applicant related to the
factors that may impact or result in
low enrollment in the waiver
request.

Section 4
Document
Upload
Templates

4.2 Minimum
Enrollment Waiver
Request Upload

CMS has revised the partial county
guidance to eliminate the use of the
inability to establish economically
viable contracts as a partial county
justification.

Section 4
Document
Upload
Templates

4.10 Partial County
Justification

4

Level of
Applicant
Burden I =
Increases
Category of burden
Comment D –
Decreases
burden
N – No
Change
60 –day
I

60-day

D

2017 High Level Summary of Change or Crosswalk of Changes for
PRA Package CMS 10237: Part C - MA and 1876 Cost Plan Expansion Application

Revision/Clarification

Purpose of the
Revision/Clarification

2017 Part C
Application

Application
Section

Level of
Applicant
Burden
I=
Category of Increase
Comment s burden
D–
Decrease
s burden
N – No
Change

HSD INSTRUCTIONS, TABLES AND EXCEPTION PROCESS
1. Exception Request template will be
revised to reflect the deletion of the
reference to Pattern of Care as
justification for an exception to be
replaced with Other Factors in
accordance with 42 CFR 422.112
a(10)(v)that CMS determines are
relevant in setting a standard for an
acceptable health care delivery
network in a particular service area. In
addition the Exception Request
template will be revised and
automated within HPMS.

The automation of the Exception
Request template will improve the
efficiency and reduce burden related
to the submission and review of the
Exception requests.

Exception
Request
Template
and HSD
Instructions

N/A

30-day

D

2. Added definitions for both the MA
Provider and Facility Types.

To provide clarification to the
applicants in the completion of the
HSD Tables.

HSD
Instructions

N/A

60-day

N

5

2017 High Level Summary of Change or Crosswalk of Changes for
PRA Package CMS 10237: Part C - MA and 1876 Cost Plan Expansion Application

Revision/Clarification

3.

4.

5.

Purpose of the
Revision/Clarification

Deleted the requirement to collect the
Provider Previously Listed from the
MA Provider HSD Table and HSD
Instructions. CMS uses automated
reports for HSD table reviews.
Deleted the requirement to collect the
Employment Status from the MA
Provider HSD Table and HSD
Instructions. This data is not used by
CMS.

CMS no longer reviews tables
manually.

Service Area Expansion (SAE)
applications will require HSD Tables
for the entire MAO network not just
the counties the plan is proposing to
expand into with the SAE request.

Provides support and focus to CMS
commitment to monitoring network
adequacy for MA.

CMS no longer needs to collect the
Employment Status.

6

MA
Provider
HSD Table
and HSD
Instructions
MA
Provider
HSD Table
and HSD
Instructions

N/A

Level of
Applicant
Burden
I=
Category of Increase
Comment s burden
D–
Decrease
s burden
N – No
Change
60-day
D

N/A

60-day

D

HSD
Instructions

N/A

60-day

I

2017 Part C
Application

Application
Section

2017 High Level Summary of Change or Crosswalk of Changes for
PRA Package CMS 10237: Part C - MA and 1876 Cost Plan Expansion Application

Revision/Clarification

Purpose of the
Revision/Clarification

2017 Part C
Application

Application
Section

Level of
Applicant
Burden
I=
Category Increas
es
of
Comment burden
D–
Decreas
es
burden

APPENDIX I: Solicitations for Special Needs Plan (SNP) Application
1. Reduced the number of attestations for the
SNP Quality Improvement Program from
28 to18.

CMS provided clarification
regarding requirements for SNP
Quality Improvement Program.

Appendix ISNP
Proposal

2. Deleted the requirement for upload of both CMS will no longer collect the QI
the Quality Improvement Program Plan and plans and QIP Matrix.
QIP Matrix upload documents.

Appendix ISNP
Proposal

3. Deleted requirement for submission of
MOC Matrix Upload Document and the
MOC Narrative for applicants submitting
SAE application.

Appendix ISNP
Proposal

CMS will no longer require MOC
for SNP applications requesting
SAE.

7

5.11 SNP Quality
Improvement
Program
Requirements

5.4 SNP Service
Area
Expansion(SAE)

60-day

D

60-day

D

60-day

D