Crosswalk

2018 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

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

1

Application
Section

All Sections

Category
of
Comment

N/A

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

2018 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

1. Chart of Required Attestations by
Type of Applicant - Revised chart
in Section 2.8 to indicate fiscal
soundness attestation based upon
application type. The chart
indicates that under attestation
topic “Fiscal Soundness” section
3.7A applies to both Initial and
Service Area Expansion (SAE)
applicants and section 3.7B
applies to Initial applicants only.

Purpose of the
Revision/Clarification

2017 Part C
Application

SUBSTANTIVE CHANGES
The chart was revised to provide the Section 2
applicants with clarification in
Instructions
identifying fiscal soundness
requirements.

2

Application
Section

Category
of
Comment

2.8 Chart of Required 30 day
Attestations by Type
of Applicant

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

2018 High Level Summary of Change or Crosswalk of Changes for
PRA Package CMS 10237: Part C - MA and 1876 Cost Plan Expansion Application

2. Revised language in section 2.9
Health Services Delivery (HSD)
Tables Instructions to clarify the
information the applicants will
need to provide related to the HSD
related documents submitted
during the Part C application
process.

CMS clarified the instructions for
applicants regarding the submission
and process for HSD tables and
Exception Requests based upon
public comments received in
response to the 60 day comment
period.

Section 2
Instructions

2.9 Health Services
Delivery (HSD)
Tables Instructions

30 day

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

3. Administrative Management Revised language in section 3.2
Administrative Management to
clarify the information in regards
to the 2 year ban for applicants
that have non-renewed or
terminated contracts within the
past 2 years.

CMS clarified the information for
the 2 year ban period and inserted
the date for 2 year period for the
current application cycle.

Section 3
Attestations

3.2 Administrative
Management

60 day

N

Revision/Clarification

Purpose of the
Revision/Clarification

2017 Part C
Application

3

Application
Section

Category
of
Comment

2018 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

4. State Licensure - Added a new
attestation to section 3.3 #6
requesting the applicant to attest
that their license automatically
renews, rather than one that will
expire without renewal. In 30 day
package deleted #7 attestation as it
was combined with # 6.

Purpose of the
Revision/Clarification

2017 Part C
Application

CMS clarified the information
regarding licensure requirements
which should reduce the number of
deficiencies related to licenses that
automatically renew after the
applications are due.

4

Section 3
Attestations

Application
Section

3.3 State Licensure

Category
of
Comment

30 day

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

2018 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

5. Fiscal Soundness- Updated fiscal
soundness attestation in section
3.7B to reflect this attestation
applies to Initial applicants only,
inserted regulatory cite 42 CFR
§422.504(a) (14) in attestation and
clarification related to CMS
expectation for SAE applicants
accuracy of response to the
attestation.

Purpose of the
Revision/Clarification

2017 Part C
Application

Section 3
Attestations

CMS clarified the information
related to the fiscal soundness
requirements.

5

Application
Section

3.7 Fiscal Soundness

Category
of
Comment

30 day

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

2018 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

Category
of
Comment

60 day

6. CMS Provider Participation
Contracts & Agreements - Deleted
attestations #5, #6, and #7 to
Section 3.9 of the application.

CMS removed the attestations due
to duplicative and redundant
language.

Section 3
Attestations

3.9 CMS Provider
Participation
Contracts &
Agreements

7. Health Services Management and
Delivery - Revised attestation #5 Applicant has verified that
contracted providers included in
the MA Facility Table are
Medicare certified, if applicable,
and the applicant certifies that it
will only contract with Medicare
certified providers in the future.

CMS clarified the information for
applicants regarding Medicare
certification requirements based
upon public comments received in
response to the 60 day comment
period. Medicare certification is
only required for applicable
providers and facilities.

Section 3
Attestations

3.11 Health Services 30 day
Management and
Delivery

6

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

N

2018 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

Category
of
Comment

8. Health Service Delivery – Two
attestations added #9 and #10 for
RPPO applicants related to
network requirements and
contracting agreements .In
addition RPPO upload template
added to section 4.6. In the 30 day
package attestation #9 was revised
to include regulatory cite.42 CFR
422.112(a)(1)(ii)).

CMS clarified the information for
RPPO applicants regarding the
network requirements and contract
agreements. The volume of RPPO
applicants has been extremely
minimal in previous application
cycles.

Section 3
Attestations

3.11 Health Services 30day
Management and
Delivery

9. Revised attestation #11 in Section
3.14 Eligibility, Enrollment, and
Disenrollment to include an
additional option for beneficiaries
to make a disenrollment request by
calling 1-800-MEDICARE.

CMS clarified the information
regarding options for disenrollment
request to include a third option. In
previous versions two options were
listed.

Section 3
Attestations

3.14 Eligibility,
Enrollment, and
Disenrollment

7

60 day

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

N

2018 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

10. State Licensure - Added a new
attestation to 8.1 #4 requesting the
applicant to attest that their license
automatically renews, rather than
one that will expire without
renewal.

Purpose of the
Revision/Clarification

2017 Part C
Application

CMS clarified the information for
applicants regarding licensure
requirements which should reduce
the number of deficiencies related
to licenses that automatically renew
after the applications are due.

8

Application
Section

Section 8
8.1 State Licensure
APPENDIX IV:
Medicare Cost
Plan Service
Area Expansion
Application

Category
of
Comment

30 day

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

2018 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.

HSD Instructions - Revised the HSD
Instructions to reflect the deletion of:
 Description of MA Provider
Types
 Description of MA Facility
Types
 CMS Certification Number
(CCN) from MA Facility
Table - Column Explanations

2. MA Facility Table - Deleted the
requirement to collect the CMS
Certification Number (CCN) column
from the MA Facility Table.

CMS clarified the information for
HSD
applicants regarding updates to HSD Instructions
instructions.

N/A

60 day

N

CMS no longer collects this
information.

N/A

60 day

D

MA Facility
Table

9

2018 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. Exception Request Template Revised the Exception Request
Template in the 30 day package to
include instructions and/or
descriptions of the content for each
section within the form.

Purpose of the
Revision/Clarification

2017 Part C
Application

CMS clarified the information for
Exception
applicants related to the Exception
Request
Request template to reflect
Template
instructions and/or descriptions of
content within the form based upon
public comments received in response
to the 60 day comment period.

1
0

Application
Section

N/A

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

2018 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
N – No
Change

APPENDIX I: Solicitations for Special Needs Plan (SNP) Application
1. I-SNP Upload Documents - Revised
required signature on I-SNP upload from
CEO to Authorized Representative and
Title.

CMS revised the signature
authority for upload document to
include both CEO and COO
based upon feedback from the
previous application cycle.

Appendix I:
SNP
Applications

5.15 I-SNP Upload
Documents

60 day

N

2. Model of Care Matrix Upload – Changed
the title to Model of Care Matrix Upload
Document for Initial Application and
Renewal and revised the matrix document
to reflect the regulatory requirements
related to each component of the Model of
Care (MOC).

CMS clarified the information for
applicants related to the
regulatory requirements in the
development of the MOC.

Appendix I:
SNP
Applications

5.17 Model of Care
Matrix Upload
Document

30 day

N

1
1