CMS 10237 Supporting Statement Part A update 30 Day

Supporting Statement Part A
Medicare Advantage Application - Part C and 1876 Cost Plan Expansion Application
Regulations under 42 CFR 422 (Subpart K) & 417.400CMS-10237, OMB 0938-0935

Background
The Balanced Budget Act of 1997 (BBA) Pub. L. 105-33, established “Part C” in the
Medicare statute (sections 1851 through 1859 of the Social Security Act (the Act)) called
Medicare+Choice. Under section 1851(a)(1) of the Act, every individual entitled to
Medicare Part A and enrolled under Part B, except for most individuals with end-stage
renal disease (ESRD), could elect to receive benefits either through the Original Medicare
Program or an Medicare+Choice plan, if one was offered where he or she lived.
The Medicare Prescription Drug, Improvement, and Modernization Act of 2003 (MMA)
Pub. L. 108-173 established the Medicare Prescription Drug Benefit Program (Part D) and
made revisions to the provisions of Medicare Part C, governing what is now called the
Medicare Advantage (MA) program (formerly Medicare+Choice). The MMA directed that
important aspects of the new Medicare Prescription Drug Benefit Program under Part D be
similar to and coordinated with regulations for the MA program. The MMA changes made
managed care more accessible, efficient, and attractive to beneficiaries seeking options to
meet their needs.
The final rules for the MA and Part D prescription drug programs appeared in the Federal
Register on January 28, 2005 (70 FR 4588 through 4741 and 70 FR 4194 through 4585,
respectively). Many of the provisions relating to applications, marketing, contracts and the
new bidding process for the MA program became effective on March 22, 2005, 60 days
after publication of the rule, so that the requirements for both programs could be
implemented by January 1, 2006.
The MA program offers several kinds of plans and health care choices which include the
following:
o Coordinated Care Plans (CCPs) – A CCP is an MA plan that offers health care
through an established provider network that is approved by the Centers for
Medicare and Medicaid Services (CMS). There are several types of plans that are
considered CCPs, including:
 Health Maintenance Organizations (HMO)
 Local Preferred Provider Organizations (LPPOs)
 Regional Preferred Provider Organizations (RPPOs)
 Special Needs Plans (SNPs)
o Medical Savings Account (MSAs) – An MSA plan is a type of MA planthat
combines a high-deductible health plan with a medical savings account.
o

Private Fee-For-Service (PFFS) Plans – A Medicare PFFS plan is a type of MA
plan that may or may not have a network of providers. Members of a PFFS plan
may see any provider who is eligible to receive payment from Medicare and
1

agrees to accept the PFFS’s terms and conditions of payment.
o Section 1876 Cost Plan – A cost contract plan is paid based on the reasonable
costs incurred by delivering Medicare-covered services to plan members.
Enrollees in these plans may use the cost plan's network of providers or receive
their health care services through Original Medicare. CMS no longer acceptsnew,
initial Cost Plan applications. However, an existing/approved Cost Plan can
submit a service area expansion (SAE) application to expand its service area.
o Employer Group Waiver Plans (EGWPs) – The MMA provides employers and
unions with a number of options for providing coverage to their Medicare –
eligible members. The EGWPs can offer various health plan types such PFFS,
CCPs, MSAs and RPPOs.
Applications for each of the plan types described above are included in this information
collection.
This information collection includes the process for organizations wishing to provide
healthcare services under MA plans. These organizations must complete an application
annually (if required), file a bid, and receive final approval from CMS. The MA application
process has two options for applicants that include (1) request for new MA product or (2)
request for expanding the service area of an existing product. CMS utilizes the application
process as the means to review, assess and determine if applicants are compliant with the
current requirements for participation in the MA program and to make a decision related to
contract award. This collection process is the only mechanism for organizations to
complete the required MA application process.
We are requesting a Revision approval from Office of Management and Budget (OMB) for
CMS-10237.
Note: Organizations that wish to offer both Part C and Part D must complete a separate Part
D application. CMS refers to these applicants as MA-PD applicants The Part D information
collection is included under OMB control number 0938-0936 (CMS-10137).
A
1.

Justification
Need and Legal Basis

This clearance request is for the vital information collection process to ensure Part C
applicants are in compliance with CMS requirements and the collection of data necessary to
support the decision related to contract awards. As noted above, organizations wishing to
provide healthcare services under MA plans must complete an application, file a bid, and
receive final approval from CMS.

2

Collection of this information is mandated by the Code of Federal Regulations, MMA, and
CMS regulations at 42 CFR 422, subpart K, in “Application Procedures and Contracts for
Medicare Advantage Organizations.” In addition, the Medicare Improvement for Patients
and Providers Act of 2008 (MIPPA) further amended titles XVII and XIX of the Social
Security Act.
2.

Information Users

CMS will collect and review information under the solicitation of Part C applications for
the various health plan product types described in the Background section above. CMS will
use the information to determine whether the applicants meet the requirements to become
an MA organization and are qualified to provide a particular type of MA plan. The
application consists of attestations and uploads that help CMS determine that the
organization:
1. Is licensed by the State (see 42 CFR 422.501(c)(1) and 422.503(b)(2);
2. Has the management, financial, and operational capabilities to operate an MA
contract (see 42 CFR 422.503(b)(4):
3. Demonstrates acceptable past performance history (see 42 CFR 422.502(b); and
4. Meets the minimum enrollment requirements to offer an MA plan (see 1857(b) and
42 CFR 422.503(b)(3).
The application process is open to all health plans that want to participate in the MA
program. The application is distinct and separate from the bid process, and CMS issues a
determination on the application prior to bid submissions, or before the first Monday in
June.
3.

Information Technology

In the application process, technology is used in the collection, processing and storage of
the data. Specifically, applicants must submit the entire application and supporting
documentation through CMS’ Health Plan Management System (HPMS). This is the case
for both the MA initial and SAE applications.
The MA application has several sections that require the applicants to respond to
attestations based upon the application type (new MA product or expanding services area
for existing MA product) and health plan type (e.g., CCP, MSA, etc.). For example, when
an applicant accesses HPMS to complete the application process for a new/initial MA
product, the applicant would be guided through the parts of the application that need to be
completed for initial applicants. Initial applicants have additional attestations than entities
that currently hold contracts with CMS, such as the requirement to complete the two
experience and organization history attestations.
Additionally, the application has documents referred to as “templates” which are forms that
need to be downloaded from HPMS, completed by the applicant, and uploaded into HPMS.
4.

Duplication of Similar Information
3

The MA application that is accessed via HPMS contains information essential for the
operation and implementation of the MA program. It is the only standardized mechanism
available to record data from organizations interested in contracting with CMS to offer an
MA plan. Where possible, we have modified the standard application to auto-populate
information that is captured in prior data collection and resides in HPMS. Otherwise, the
form does not duplicate any information currently collected.
5.

Small Business

The collection of information will have a minimal impact on small businesses since
applicants must possess an insurance license and be able to accept substantial financial risk.
Generally, state statutory licensure requirements effectively preclude small businesses from
being licensed to bear risk needed to serve Medicare enrollees.
6.

Less Frequent Collection

This is an annual collection. If this information were collected less frequently, CMS will
have no mechanism to allow new applicants an opportunity to demonstrate that applicants
meet the CMS requirements and support determination of contract awards or denials.
7.

Special Circumstances

Each applicant is required to enter and maintain data in the HPMS. Prompt entry and
ongoing maintenance of the data in HPMS will facilitate the tracing of the applicant’s
application throughout the review process. If the applicant is awarded a contract after
negotiation, the collection of information will be used for frequent communications during
implementation of the MA organization’s program. Applicants are expected to ensure the
accuracy of the collected information on an ongoing basis.
8.Federal Register Notice/Outside Consultation
Federal Register Notices & Comments

9.

60 Day Notice:
Volume: 83
Page number: 43689
Number of Comments: 2

Publication date: 8/27/2018

30 Day Notice:
Volume
Page number
Number of Comments

Publication date

Payment/Gift to Respondent

While there are no gifts associated with this collection, the application is required to receive
a government contract.
4

10.

Confidentiality

Consistent with federal government and CMS policies, CMS will protect the confidentiality
of the requested proprietary information. Specifically, only information within a submitted
application (or attachments thereto) that constitutes a trade secret, privileged or confidential
information, (as such terms are interpreted under the Freedom of Information Act and
applicable case law), and is clearly labeled as such by the applicant, and which includes an
explanation of how it meets one of the expectations specified n 45 CFR Part 5, will be
protected from release by CMS under 5 U.S.C. §552(b)(4). Information not labeled as
trade secret, privileged, confidential or does not include an explanation of why it meets
one or more of the Freedom of Information Act exceptions in 45 CFR Part 5 will not be
withheld from release under 5 U.S. C. §552(b)(4).
11.

Sensitive Questions

Other than the labeled information noted above in section 10, there are no sensitive
questions included in the information request.
12.

Burden Estimate (Total Hours & Wages)

12.1.

Wages

To derive average costs, we used data from the U.S. Bureau of Labor Statistics’ (BLS) May
2017 National Occupational Employment and Wage Estimates for all salary estimates
(http://www.bls.gov/oes/current/oes_nat.htm). We selected the position of Compliance
Officer because this position is a key contact identified by MA plans. CMS typically
interacts with the Compliance Officer in matters related to the Part C/MA application after
it is submitted to CMS. In this regard, the following table presents the mean hourly wage,
the cost of fringe benefits (calculated at 100 percent of salary), and the adjusted hourly
wage.
Table 1 – BLS Labor Rate
Occupation
Occupation
Title
Code
Compliance
Officers

13-1041

Mean Hourly
Wage ($/hr)

Fringe Benefit
($/hr)

34.39

34.39

Adjusted
Hourly Wage
($/hr)
68.78

As indicated, we are adjusting our employee hourly wage estimates by a factor of 100
percent. This is necessarily a rough adjustment, both because (1) fringe benefits and
overhead costs vary significantly from employer to employer, and (2) because methods of
estimating these costs vary widely from study to study. Nonetheless, there is no practical
alternative, and we believe that doubling the hourly wage to estimate total cost is a
reasonably accurate estimation method.
12.2.

Requirements and Associated Burden Estimates
5

Organizations wishing to provide healthcare services under Part C/MA plans must
complete an application, file a bid, and receive final approval from CMS. Existing Part
C/MA plans may request to expand their contracted service area by completing the SAE
application.
This clearance request is for information collection of the health plan types described in the
Background section of this document. The application process is open to all health plans
that want to participate in the Part C/MA program.
12.2.1.

Time by Application Type

In total, for CY 2020 CMS estimates that it will receive 400 applications. This would
amount to 6,106 total annual hours. The estimated burden hours are based on an internal
assessment of application materials that are required for submission by the applicants. The
application process has two options for applicants that include (1) request for new MA
product, or (2) request for expanding the service area of an existing product. If an applicant
is applying for a new MA product then the application process would be longer because the
required completion of attestations and potential templates that need to be completed will
require more effort than an applicant that is requesting to expand their service area via the
SAE application.
The chart below describes types of MA product types (as described in the Background
section) that can submit applications. The chart is identifying application options in terms
of initial applications and SAE applications (NOTE: No new 1876 Cost Plans can submit
new applications).
Table 2 – Summary of Annual Burden Hours
Initial
(CCP,
PFFSNetwork,
MSANetwork,
EGWP )

Application/
Responses

Expected
Applications/
Responses
Review Instructions
(#of hours)
Complete
Application /
Proposal (# of
hours)
Estimated # of
hours per
application
/proposal
Annual Burden
hours

PFFS
MSA
(Initial(Initial
SNP
NonNonInitial
network) Network)

SAE
(CCP,
PFFSNetwork,
MSANetwork
EGWP)

SNP
SAE

PFFS
MSA
Cost
(SAE(SAE Direct
Plan Summary
NonNon- EGWP
SAE
network) Network)

60

80

0

1

170

86

2

0

0

1

400

1.0

1.0

1.0*

1

0.5

0.5

.5

.5*

0.5*

0.5

5

32.0

9.0

32.0*

32.0

15.0

6.5

18.5

21*

0.5*

17.5

132

33

10

33*

33

15.5

7

19

21.5*

1*

18

137

1,980

800

0

33

2,635

602

38

0

0

18

6,106

*Numbers not included in Summary column given expected workload of 0.

12.2.2.

Cost by Application Type

The estimated wage burden for the MA Part C Application is $419,970 based on an
6

estimate wage rate of $68.78/hr wage. The median cost per application is $1,238 (18 hours
* $68.78= $1,238).
Table 3 – Summary of Industry Wage Burden
Application/
Responses

Annual burden
Hours

Initial
SAE (CCP,
PFFS
(CCP, PFFSPFFSSNP (Initial- MSA Network, SNP
Network,
Initial Non- (Initial) MSAMSASAE
Network
network)
Network
EGWP )
EGWP)
1,980

800

$68.78

$68.78

$136,184

$55,024

0

33

$68.78 $68.78

PFFS
MSA
(SAE
(SA
Direct
EGWP
E
NonNonnetwork) Network)

Cost
Plan
SAE

Total

2,635

602

38

0

0

18

6,106

$68.78

$68.78

$68.78

$68.78

$68.78

$68.78

$68.78

$0

$0

Per Hour
Wages
Total Wage
burden

12.3.


$0

$2,270

$181,235 $41,405 $2,614

$1,238 $419,970

Information Collection Attachments

Part C -Medicare Advantage and 1876 Cost Plan Expansion Application

Part C -Medicare Advantage and 1876 Cost Plan Expansion Application is submitted
electronically via HPMS. CMS provides the paper version of the application in the annual
Part C PRA package. The table of contents identifies the key components of the
application, which are also summarized below.
(1) General Information – This section provides overview of the MA program,
description of MA product types, description of HPMS, key due dates related to
the application process;
(2) Instructions – This section provides general information on how to complete
the application process , specific instructions related to certain health plan
product types such as EGWPs, SNPs and Cost Plans, and a chart is provided that
summarizes the various attestations that are required to be completed by the
applicant based upon heath plan type;
(3) Attestations – This section has all the attestations that are utilized in the
application process by both new MA product applicants and SAE applicants.
The required attestations for a new MA product applicant is greater than the
number of attestations required for an SAE applicant (See chartbelow);
(4) Document Upload Templates – This section has all the required templates that
an applicant may need to complete based upon the type of application and /or
health plan type. Currently there are 10 upload documents in this area of the
application;
(5) Appendix 1- Solicitations for Special Needs Plan (SNP) Application – This
section includes the application for applicants that want to offer a SNP. This
section would be completed to reflect the type of SNP and population of
beneficiaries the applicant wants to serve. Note this section also has some
7

specific attestations and template upload documents that are required for SNP
applicants;
(6) Appendix II- Employer/union – Only Group Waiver Plans (EGWPs) MAO
“800” Series – this section is specific to EGWP applicants only. As noted above
for the SNP section this section also has attestations and/or upload documents
that are specific to this application type.
(7) Appendix III- Employer/Union Direct Contract for MA – This section has
specific requirements for this health plan type that the applicant is required to
complete.
(8) Appendix IV-Medicare Cost Plan Service Area Expansion Application –
This section is required for any existing Cost Plan that wants to request an
expansion in their service area. Note: no new application for Cost Plans can be
submitted to CMS.
HPMS is the primary information collection vehicle through which organizations will
communicate with CMS during the application process, bid submission process, ongoing
operations of the MA program or Medicare Cost Plan contracts, and reporting and oversight
activities.
Table 4 - Chart of Required Attestations by Application Type (non-SNP)
Attestation Section
Name

Section
#

Initial Applicants

Service Area Expansion

CCP

PFFS

RPPO

MSA

CCP

PFFS

RPPO

MSA

COST

3.1

X

X

X

X

3.2

X

X

X

X

X

X

X

X

X

State Licensure

3.3

X

X

X

X

X

X

X

X

X

Program Integrity

3.4

X

X

X

X

Compliance Plan

3.5

X

X

X

X

Key Management
Staff

3.6

X

X

X

X

Fiscal Soundness

3.7

X

X

X

X

X

X

X

X

Service Area

3.8

X

X*

X

X*

X

X*

X

X*

X

3.9

X

X

X

X

X

X

X

X

X

3.10

X

X

X

X

X

X

X

X

X

3.11

X

X

X

X

3.12

X

X

X

X

3.13

X

X

X

X

3.14

X

X

X

X

Claims

3.15

X

X

X

X

Communication

3.16

X

X

X

X

Management,
Experience, and
History
Administrative
Management

CMS Provider
Participation
Contracts &
Agreements
Contracts for
Administrative &
Management
Services
Quality Improvement
Program
Marketing
Eligibility, Enrollment,
and Disenrollment,
Working Aged
Membership

8

Attestation Section
Name

Section
#

Initial Applicants

Service Area Expansion

CCP

PFFS

RPPO

MSA

CCP

PFFS

RPPO

MSA

3.17

X

X

X

X

3.18

X

X

X

X

3.19

X

X

X

X

Continuation Area

3.20

X

X

X

Part C Application
Certification

X

X

X

X

X

3.21

X

X

X

X

X

X

X

X

Access to Services

3.22

X

Claims Processing

3.23

X

X

X

X

Payment Provisions

3.24

X

X

X

X

General
Administration/
Management

3.25

Past Performance

3.26

COST

between MAO and
CMS
Grievances
Organization
Determination and
Appeals
Health Insurance
Portability and
Accountability Act of
1996 (HIPAA)

X

X
X

X

X

X

X

X
X

X

X

X

X

*Applies to network PFFS and MSA applicants.

13.

Capital Cost (Maintenance of Capital Costs)

We do not anticipate additional capital costs. CMS requirements do not require the
acquisition of new systems or the development of new technology to complete the
application.
System requirements for submitting HPMS applicant information are minimal. MAOs will
need the following access to HPMS: (1) Internet or Medicare Data Communications
Network (MDCN) connectivity, (2) use of Microsoft Internet Explorer web browser
(version 5.1 or higher) with 128-bits encryption and (3) a CMS-issued user ID and
password with access rights to HPMS for each user within the MAO’s organization who
will require such access. CMS anticipates that all qualified applicants meet these system
requirements and will not incur additional capital costs.
14.

Cost to Federal Government

To derive average costs, we used data from the Office of Personnel Management’s (OPM)
2017 Salary Table for the Washington-Baltimore-Northern Virginia locality
(https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salarytables/18Tables/html/DCB_h.aspx). The following table presents the hourly wage, the cost
of fringe benefits (calculated at 100 percent of salary), and the adjusted hourly wage.

9

Table 5 – Occupation-Specific OPM Labor Rates
Occupation

Grade/Step

Wage
($/hr)

Regional Office Account Managers/
Central Office Health Insurance Specialist
Regional Office Supervisor

13/5
14/5

52.66

Fringe
Benefit
($/hr)
52.66

Adjusted
Hourly Wage
($/hr)
105.32

62.23

62.33

124.66

As indicated, we are adjusting our employee hourly wage estimates by a factor of 100
percent. This is necessarily a rough adjustment, both because (1) fringe benefits and
overhead costs vary significantly from employer to employer, and (2) because methods of
estimating these costs vary widely from study to study. Nonetheless, there is no practical
alternative and we believe that doubling the hourly wage to estimate total cost is a
reasonably accurate estimation method.
Our estimated cost is based on the budgeted amount for application review and estimate
wages of key reviewers and support staff. Note the Part C applications are submitted by
various MA plans across the country.
The primary review of the Part C applications is the responsibility of Regional Office staff
which is usually at the GS 13 level with position type such as RO Account Managers. In
addition, the Central Office staff (primarily in the Medicare Drug & Health Plan Contract
Administration Group (MCAG) is also required to perform some portions of the Part C
application review process which is usually of the GS 13 grade level and position type such
as Health Insurance Specialist.
Regional Office Supervisor is requested to confirm the RO staff review decisions. The RO
Supervisor is usually at the GS14 grade level.
Table 6 - Annualized Cost to Federal Government
CMS Staff
HPMS
Systems
staff
Central
Office
Health
Insurance
Specialist
Regional
Office
Account
Manager
Regional
Office
Supervisor
Total

Hour per
Application

Application
Volume

Total
Hours

Hourly
Rate

Projected
Costs

Cost per
Application

4

400

1600

$105.32

$168,512

$421

4

400

1600

$105.32

$168,512

$421

10

400

4000

$105.32

$421,280

$1,053

4

400

1600

$124.66

$199,456

$499

22

-

8,800

-

$957,760

$2,394

10

15.

Program or Burden Changes

There are significant changes to the burden estimates for CY 2020 when compared to CY
2019 (and prior years). These changes are:




Changes in labor rates;
Reductions in application sections and attestations;
Reductions in applicationuploads

Table 7 provides a summary comparison burden estimates between CY 2019 and CY
2020.
Table 7 - Summary of Burden Hours Comparison CY2019 to CY2020
CY2019
Number of
Respondents

CY 2019
Estimates
(hours)

CY2019
Annual Burden
Hours

CY2020
Number of
Respondents

CY 2020
Estimates
(hours)

CY2020
Annual Burden
Hours

Initial (CCP,PFFSNetwork, MSA,Network, EGWP )

50

33

1,650

60

33

1,980

SNP Initial

75

11

825

80

10

800

0

33

0

0

33

0

1

33

33

1

33

33

167

18

3,006

170

15.5

2,635

SNP SAE

84

8

672

86

7

602

SNP Renewal
Only

0

0

0

0

0

0

2

21

42

2

19

38

0

23.5

0

0

21.5

0

PFFS nonNetwork (initials)
MSA nonNetwork (initials)
SAE (CCP,PFFSNetwork, MSA,Network, EGWP )

PFFS
(SAE- Nonnetwork)
MSA
(SAE- Nonnetwork)
Direct EGWP

0

1

0

0

1

0

Cost Plan
SAE

1

18

18

1

18

18

Total

380

199.5

6,246

400

191

6,106

Table 8 below provides additional detail regarding the changes in hours between the CY
2019 and CY 2020 applications. The narrative explanation for the reduction in burden for
the attestations and uploads is provided in section 15.3 through 15.5 below.
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Table 8: Changes in Burden Across Attestations and Uploads
Application
Type

Burden
Category

Initial CCP

Instructions

SAE MSA
Nonnetwork

SAE Cost
Plan

0
0
0

Total
Instructions

70
N/A

33
1

70
N/A

33
1

0
N/A

0
0

Attestations

39

2

39

2.0

0

0

6

8

5

7

-1

-1

45

11

44

10

-1

-1

N/A
68
18

1
6
26

N/A
68
18

1
6
26

N/A
0
0

0
0
0

86

33

86

33

0

0

N/A
65

1
6

N/A
65

1
6

N/A
0

0
0

Uploads

19

26

19

26

0

0

Total

84

33

84

33

0

0

N/A
26
12

.5
2.5
15

N/A
24
10

0.5
2
13

N/A
-2
-2

0
-.5
-2

38

18

34

15.5

-4

-2.5

N/A
21

.5
1.5

N/A
21

0.5
1.5

N/A
0

0
0

5

6

4

5

-1

-1

Total
Instructions

26
N/A

8
0.5

25
N/A

7
0.5

-1
N/A

-1
0

Attestations

37

1.5

36

1.5

-1

0

Uploads

16

19

14

17

-2

-2

Total
Instructions

53
N/A

21
0.5

50
N/A

19
0.5

-3
N/A

-2
0

Attestations

34

3

33

3

-1

0

Uploads

17

20

15

18

2

-2

Total
Instructions

51
N/A

23.5
0.5

48
N/A

21.5
0.5

-3
N/A

-2
0

Attestations

19

2.5

19

2.5

0

0

7

15

7

15

0

0

26

18

26

18

0

0

Instructions
Attestations
Uploads

Instructions
Attestations

Instructions
Attestations
Uploads

Instructions
Attestations
Uploads

SAE PFFS
NonNetwork

1

Difference
Hours
N/A
0
0

Total
SAE SNP

Number
6
26

Total

SAE CCP*

1

2020
Hours
N/A
56
14

Total

Initial MSA
Nonnetwork

Number
6
26

Uploads

Initial PFFS
NonNetwork

2019
Hours
N/A
56
14

Attestations
Uploads
Initial SNP*

Number

Uploads
Total

*SNP application attestations and uploads vary slightly by application type.

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In addition to changes to CMS’s burden estimate for industry, we estimate significant
Government burden estimates will remain constant, which are shown in the table below.
Table 9 - Summary of Government Burden Changes: Hours Per Application
CY 2019
CY 2020
CMS Staff
Difference
Hours
Hours
0
HPMS Systems staff
4
4
0
Central Office Health Insurance Specialist
4
4
0
Regional Office Account Manager
10
10
0
Regional Office Specialist HSD Review
0
0
0
Regional Office Supervisor
4
4
0
SNP Clinical
0
0
22
22
0
Total
The sections below provide additional detail to support the changes described above.
15.1.

Burden Changes Driven by Workload Volumes

For the CY 2019 application cycle, CMS had an approximate 20% increase in MA SAE
applications. We believe this increase corresponds with the implementation of the triennial
review. CMS also had an approximate increase of 11% in MA initial applications. We
believe that this increase was also due to increased industry preparedness. Based on
comparing the CY 2019 data to CYs 2015-2018, the CY 2019 volumes align with historic
trends.
Similar to CY 2019 MA application volumes, CMS had an increase in SNP applications in
CY 2019 as compared to CY 2018. CMS noted an approximate 62% increase in the number
of SNP initial applications submitted in CY 2019 when compared to CY 2018, and an
increase of 3% SNP SAE applications. Organizations seeking SNP applications must first
be qualified in the respective SNP service area through the MA application process.
Therefore, initial SNP applications often have corresponding initial MA applications. CMS
also sees MA SAE applications submitted when a SNP wants to expand their service area
to offer services in a new state or county.
Given the fluctuations between CY 2018 and 2019, CMS estimated the CY 2020
application workloads in Table 9 below by analyzing application receipt data from CYs
2014-2018. CMS calculated the CY 2020 workload by taking the median across these
years, but excluded CY 2014 as an outlier since the initial workload volumes were
significantly higher than any other year.

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Table 10 - Workload Comparison: CY 2018 and CY 2019
Application/
Responses

CY 2019
Expected
Applications/
Responses
CY 2020
Expected
Applications/
Responses
Difference

15.2.

Initial
(CCP,
PFFSNetwork,
MSANetwork
EGWP )

Initial
with
SNP

PFFS
(InitialNonnetwork)

MSA
(Initial
NonNetwork)

SAE
(CCP,
PFFSNetwork,
MSANetwork,
EGWP)

SAE
with
SNP

PFFS
(SAENonnetwork)

MSA
(SAE
NonNetwor
k

50

75

0

1

167

84

2

60

80

0

1

170

86

+10

+5

0

0

+3

+2

Direct
EGWP

Cost
Plan
SAE

Summary

0

0

1

380

2

0

0

1

400

0

0

0

0

+20

Burden Changes Drive by Labor Rate Adjustments

For industry burden, we have adjusted our cost estimates by using the most
recent BLS wage data, as discussed in section 12.1 above. Similarly, for
CMS burden, we have adjusted our cost estimates by using the most recent
labor rate calculated by OPM, as discussed in section 14 above.
Table 11 - Labor Rate Comparison: CY 2018 and CY 2019
CY 2019
CY 2019
BLS Hourly Rate
$67.54
$68.78
OMB Hourly Rate – GS-13
$102.96
$105.32
OMB Hourly Rate – GS-14
$121.66
$124.66
15.3.

Difference
+$1.24
+2.36
+3.00

Burden Changes Driven by Application Section and Attestation Reductions

CMS removed two MA application sections as well as combined several
attestations in order to streamline the application. CMS also consolidated the
Key Personnel and Compliance Plan section of the application with the
Experience and History Section. CMS does not estimate a significant reduction
based on these changes.
15.4.

Burden Changes Driven by Upload Reductions

CMS removed one (1) SNP and one (1) MA upload requirement to
streamline the application.
1. CMS removed the Health Risk Assessment Tool (HRAT) upload
associated SNP applications. CMS will no longer require
organizations to submit the HRAT upload. CMS estimates a
reduction of one (1) hour based on the removal of this upload.
2. CMS removed the Regional Preferred Provider Organization
(RPPO) upload associated with MAapplications.
15.5.

Title Change
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The current title of this information collection request is, “Medicare
Advantage Application - Part C and 1876 Cost Plan Expansion
Application Regulations under 42 CFR 422 (Subpart K) & 417.400.” In
this iteration we are revising the title to read, “Applications for Part C
Medicare Advantage, 1876 Cost Plans, and Employer Group Waiver
Plans to Provide Part C Benefits.”
16. Publication and Tabulation Dates
This information is not published or tabulated.
17.

Expiration Date

CMS is not requesting an exemption from displaying the expiration date. Note this
collection request is submitted annually for the Part C application.
18. Certification Statement
There are no exceptions to the certification statement.
B. Collection of Information Employing Statistical Methods
There has been no statistical method employed in this collection.

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