CMS-10725 - Crosswalk

Revisions to Appendices for Pharmacy Benefit Manager Transparency for Qualified Health Plans
(CMS-10725/OMB control number: 0938-NEW)
Issue

Appendix

1

A, B

Appendix Page
Number
1

2

A, B, C, D

3

Reason for the change and accompanying worksheets

Burden Effect

Appendix A for the 60 day PRA Notice was an Excel worksheet
with two tabs for collecting summary-level data and detailedlevel data, respectively. We removed the summary-level data
tab from the Excel spreadsheet, and will require submission of
the data via web form instead. The mockup for the web form is
new Appendix A. The Excel Worksheet that was formerly
Appendix A is now Appendix B and only contains one tab for
detailed-level data.

None.

1

Separating the two tabs in the Excel spreadsheet that was
former Appendix A created an additional Appendix that
required relettering the other Appendices. Former Appendix A
is now Appendix B. The instructions document which was
former Appendix B is now Appendix C. The PBM attestation
which was former Appendix C is now Appendix D.

None.

A

1

The field for bona fide services fees was removed from the
summary-level data fields because there is no statutory
authorization to collect such data.

The removal of one summary level
field will have a negligible impact
on lowering burden.

4

C

1

Added introduction and instructions for submitters to submit
Appendices A, B, D, and E, which were not included in the 60
day notice. Submitters need this instruction in order to report
data properly.

None.

5

C

2-6

Added sample allocation methodologies to account for
differences in how data is currently held by submitters.

None.

Revisions to Appendices for Pharmacy Benefit Manager Transparency for Qualified Health Plans
(CMS-10725/OMB control number: 0938-NEW)
Issue

Appendix

6

E

Appendix Page
Number
1

7

A, C

A1, C8

Reason for the change and accompanying worksheets

Burden Effect

Added an attestation for QHP issuers to fill out to attest to the
data's accuracy, completeness, and truthfulness when the QHP
does not contract with a PBM to administer their prescription
drug benefit.

None. There is no QHP issuer that
does not contract with a PBM. We
have made this attestation
available for any instance in which
a QHP issuer does not contract with
a PBM and must report the data
themselves.

Changed from plan year reporting to calendar year reporting to
simplify collection. Requiring plan year reporting may have
small group QHPs or their PBMs submitting data for a plan year
which ended many months after the calendar year. Requiring
all plans to submit on a calendar year basis will standardize
when all data will be submitted.

None.