Crosswalk/Substantive Change

10/14/2020
Summary of Substantive and Technical Changes for
All Part D Application Revisions from 2020 Version of Part D Application to 2022

Substantive Changes
Clarification

Purpose of Clarification

None

1

PDP/MAPD

PACE

Change in
Burden

10/14/2020
Summary of Substantive and Technical Changes for
All Part D Application Revisions from 2020 Version of Part D Application to 2022

Technical Changes
Clarification

Purpose of Clarification

PDP/MAPD

1. Changed dates throughout document to reflect changes for
2022 application cycle.

To reflect changes for 2022 cycle.

Throughout
document

2. Grammatical and wording changes.

To enhance readability.

3. Updated references to regulatory requirements and guidance,
including removing any reference to the “Call Letter”.
4. Added language in section 2.4 to clarify requirement that
application be complete, that the current instructions must be
used, and that applicants cannot rely on their understanding of
prior years’ applications in determining whether they are
compliant with the 2022 application requirements.
5. Added sample chart of relationship between the applicant and
its first tier, downstream, and related entities.
6. Added clarifying language to the description of the required
payment element for first tier, downstream, and related entity
contracts.

To reflect changes for 2022 cycle and provide more
precision in references and language.
To reflect claims made by applicants during the 2021
application period that they relied on their understanding
of prior years’ applications to interpret the current
application requirement
To assist applicants who aren’t sure how to structure the
requested chart.
To clarify that payment terms must be agreed to by the
parties and that the terms may not be redacted.

7. Removed list of contacts to be completed in HPMS

To streamline the application. The list of contacts in
HPMS is determined outside the application process
and there is no need to duplicate the list in the
solicitation, in particular because the list may change.
HPMS requirements go through a separate PRA
process.
NOTE 1: Nothing in the technical changes table increases burden on the applicant.

2

Throughout
document
Throughout
Document
Section 2.4, p
9

Section
3.1.1.D, p. 30
Section
3.1.1.E, item
5, p 31

Section 3.1.4
A, p 37. Also
reflected in
crosswalk,
Appendix X, p
110

PACE

Throughout
document
Throughout
document
Throughout
Document
Section 2.1,
p. 9

Section
3.1.2, p 16
Section
3.1.3, item 5,
p 18. Also
reflected in
crosswalk, p
20
Section 3.2
A, p 24