Appendix J Crosswalk

CY2022 to CY2023 DV Appendix J Crosswalk of Changes_Draft_20220714.pdf

Medicare Part C and Part D Data Validation (42 CFR 422.516(g) and 423.514(g)) (CMS-10305)

Appendix J Crosswalk

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Reporting
Section
CDR

CY 2022 DV (2021 Reporting Requirements)
RSC 12.b check for Data Element 2.B

CY 2023 DV (2022 Reporting Requirements)
RSC 12 had been changed to RSC 13 before the
PRM.

Type of
Change

Reason for
Change

Burden
Change

Deletion

Consistent
with current
technical
guidance.

None

Deletion

Consistent
with current
technical
guidance.

None

Deletion

Consistent
with current
technical
guidance.

None

Row for RSC 13.b which checks for Data Element
2.B has been deleted.
CDR

MTM

RSC 12.c: Each number calculated for requests
for redeterminations that were withdrawn (Data
Element 2.B) and requests for redeterminations
that were dismissed (Data Element 2.C) is a
subset of the number of redeterminations
decisions made (Data Element 2.A).

RSC 12 had been changed to RSC 13 before the
PRM.
RSC 13.c has been deleted.

RSC 5v. If a CMR was offered (Data Element N), RSC 5v has been deleted.
there is a reported recipient of initial offer (Data
Element P ≠ missing).  
Data Element P

MTM

RSC 5w

RSC code has been revised to RSC 5v

Update

Consistent
with current
technical
guidance.

None

MTM

RSC 5x

RSC code has been revised to RSC 5w

Update

Consistent
with current
technical
guidance.

None

Reporting
Section

CY 2022 DV (2021 Reporting Requirements)

CY 2023 DV (2022 Reporting Requirements)

Type of
Change

Reason for
Change

Burden
Change

MTM

RSC 5y

RSC code has been revised to RSC 5x

Update

Consistent
with current
technical
guidance.

None

MTM

RSC 5z

RSC code has been revised to RSC 5y

Update

Consistent
with current
technical
guidance.

None

MTM

RSC 5aa

RSC code has been revised to RSC 5z

Update

Consistent
with current
technical
guidance.

None

MTM

RSC 5bb

RSC code has been revised to RSC 5aa

Update

Consistent
with current
technical
guidance.

None

MTM

RSC 5cc

RSC code has been revised to RSC 5bb

Update

Consistent
with current
technical
guidance.

None

Reporting
Section

CY 2022 DV (2021 Reporting Requirements)

CY 2023 DV (2022 Reporting Requirements)

Type of
Change

Reason for
Change

Burden
Change

MTM

RSC 5dd

RSC code has been revised to RSC 5cc

Update

Consistent
with current
technical
guidance.

None

MTM

RSC 11c. Properly identifies and includes the
number of medication therapy problem resolutions
resulting from recommendations made to
beneficiary’s prescriber(s) as a result of MTM
program services within the reporting period for
each applicable member. For reporting purposes,
a resolution is defined as a change or variation
from the beneficiary’s previous medication
therapy. Examples include, but are not limited to,
Initiate medication, Change medication (such as
product in different therapeutic class, dose,
dosage form, quantity, or interval), Discontinue or
substitute medication (such as discontinue
medication, generic substitution, or formulary
substitution), and Medication
compliance/adherence.

RSC 11c. Properly identifies and includes the
number of medication therapy problem resolutions
resulting from recommendations made to
beneficiary’s prescriber(s) as a result of MTM
program services within the reporting period for
each applicable member. For reporting purposes,
a resolution is defined as a change or variation
from the beneficiary’s previous medication therapy.
Examples include, but are not limited to, Initiate
medication, Change medication (such as product
in different therapeutic class, dose, dosage form,
quantity, or interval), Discontinue or substitute
medication (such as discontinue medication,
generic substitution, or formulary substitution), and
Medication compliance/adherence.

Update

Consistent
with current
technical
guidance.

None

Data Element Z

Data Element X

Reporting
Section

CY 2022 DV (2021 Reporting Requirements)

CY 2023 DV (2022 Reporting Requirements)

Type of
Change

Reason for
Change

Burden
Change

DUR

RSC 5-a.ii. The number of claims rejected due to
the care coordination safety edit (Element C)
should be greater than or equal to each of the
following:
• The number of claim rejections overridden by
the pharmacist at the pharmacy (Element D);
• The number of claim rejections overridden by
the pharmacy within 24 hours of the initial claim
rejection (Element E);
• The number of claim rejections overridden by
the pharmacist at the pharmacy that also had an
opioid claim successfully processed at POS
(Element F); and
• The number of claim rejections overridden by
the pharmacy as a result of prescriber
consultation (Element G).

RSC 5-a.ii. The number of claims rejected due to
the care coordination safety edit (Element C)
should be greater than or equal to each of the
following:
• The number of claim rejections overridden by the
pharmacy (Element D);
• The number of claim rejections overridden by the
pharmacy within 24 hours of the initial claim
rejection (Element E);
• The number of claim rejections overridden by the
due to an exemption (Element F); and
• The number of claim rejections overridden by the
pharmacy as a result of prescriber consultation
(Element G).

Update

Consistent
with current
technical
guidance

None

DUR

RSC 5-a.iii. The number of unique beneficiaries
with at least one claim rejected due to the care
coordination safety edit (Element F) should be
greater than or equal to the number of unique
beneficiaries with at least one claim rejection
overridden by the pharmacist at the pharmacy
(Element G) and the number of unique
beneficiaries with at least one rejection overridden
by the pharmacist at the pharmacy that also had
an opioid claim successfully processed at POS.
(Element H)

RSC 5-a.iii The number of unique beneficiaries
with at least one claim rejected due to the care
coordination safety edit (Element H) should be
greater than or equal to each of the following:
• The number of unique beneficiaries with at least
one claim rejection overridden by the pharmacy
(Element I)
• The number of unique beneficiaries with at least
one claim rejection overridden by the pharmacy
within 24 hours of the initial claim rejection
(Element J)
• The number of unique beneficiaries with at least
one claim rejection overridden by the pharmacy at
the pharmacy due to an exemption (Element K)
• The number of unique beneficiaries with at least
one claim rejection overridden by the pharmacy as
a result of prescriber consultation (Element L)

Update

Consistent
with current
technical
guidance

None

Reporting
Section

CY 2022 DV (2021 Reporting Requirements)

CY 2023 DV (2022 Reporting Requirements)

Type of
Change

Reason for
Change

Burden
Change

DUR

RSC-5.bi: The number of unique beneficiaries
with at least one claim rejected due to the hard
MME safety edit (Element M) should be greater
than or equal to each of the following:

RSC-5.bi: The number of unique beneficiaries with
at least one claim rejected due to the hard MME
safety edit (Element R) should be greater than or
equal to each of the following:

Update

Consistent
with current
technical
guidance

None

DUR

RSC 5-d.ii: The number of claims rejected due to
the opioid naïve days supply edit (Element W)
should be greater than or equal to the number of
claim rejections successfully processed at POS
other than through a favorable coverage
determination or appeal, such as pharmacist
communication and/or plan override (Element X)
and the number of claim rejections successfully
processed at POS through a favorable coverage
determination or appeal (Element Y).

RSC 5-d.ii: The number of claims rejected due to
Update
the opioid naïve days supply edit (Element W)
should be greater than or equal to each of the
following:
• the number of claim rejections overridden by the
pharmacy due to an exemption (Element X);
• the number of claim rejections overridden by the
pharmacy because the beneficiary was not opioid
naive (Element Y); and
• the number of rejected claims for which up to a 7day supply (covered by the plan) was dispensed by
the pharmacy (Element Z).

Consistent
with current
technical
guidance

None

DUR

RSC-8: The organization accurately identifies
claims leading to a coverage determination and
correctly uploads the count into HPMS including
the following criteria:

RSC-8: The organization accurately identifies
claims leading to a coverage determination request
and correctly uploads the count into HPMS
including the following criteria:

Update

Consistent
with current
technical
guidance

None

DUR

RSC-8.a. The organization accurately identifies
claims leading to a coverage determination and
correctly uploads the count into HPMS including
the following criteria:
a: From the data set (RSC6b) of POS rejects
related to the hard MME safety edits,

RSC-8.a. The organization accurately identifies
claims leading to a coverage determination request
and correctly uploads the count into HPMS
including the following criteria:
a: From the data set (RSC6b) of POS rejects
related to the hard MME safety edits,

Update

Consistent
with current
technical
guidance

None

Reporting
Section

CY 2022 DV (2021 Reporting Requirements)

Type of
Change

Reason for
Change

Burden
Change

RSC-8-aii: Includes all methods of coverage
Update
determination receipt (e.g., telephone, letter, fax, inperson).

Consistent
with current
technical
guidance

None

Update

Consistent
with current
technical
guidance

None

RSC-8: The organization accurately identifies
Update
claims leading to a coverage determination request
and correctly uploads the count into HPMS
including the following criteria:
b: From the data set (RSC6c) of POS rejects
related to the opioid naïve days supply safety edits,
RSC-8-bii: Includes all methods of coverage
Update
determination receipt (e.g., telephone, letter, fax, inperson).

Consistent
with current
technical
guidance

None

Consistent
with current
technical
guidance

None

Consistent
with current
technical
guidance

None

CY 2023 DV (2022 Reporting Requirements)

DUR

RSC-8-aii: Includes all methods of coverage
determination or appeal receipt (e.g., telephone,
letter, fax, in-person).

DUR

RSC-8-aiii: Includes all coverage determination or RSC-8-aiii: Includes all coverage determination
appeal requests.
requests.

DUR

RSC-8: The organization accurately identifies
claims leading to a coverage determination and
correctly uploads the count into HPMS including
the following criteria:
b: From the data set (RSC6c) of POS rejects
related to the opioid naïve days supply safety
RSC-8-bii: Includes all methods of coverage
determination or appeal receipt (e.g., telephone,
letter, fax, in-person).

DUR

DUR

RSC-8-biii: Includes all coverage determination or RSC-8-biii: Includes all coverage determination
appeal requests subject to the opioid naïve edit.
requests subject to the opioid naïve edit.

Update

Reporting
Section

Type of
Change

Reason for
Change

Burden
Change

RSC-9: The organization accurately identifies the
number of unique beneficiaries with at least one
POS claim rejection related to a hard MME safety
edit and/or opioid naïve days supply safety edit
who had a favorable (either full or partial) coverage
determination for the prescription(s) subject to the
edit. Correctly uploads the count, if the data set of
POS rejects includes the complete reporting
period, into HPMS including the following criteria:

Update

Consistent
with current
technical
guidance

None

RSC-9.a. - The organization accurately identifies
the number of unique beneficiaries with at least
one POS claim rejection related to a hard MME
safety edit and/or opioid naïve days supply safety
edit who had a favorable (either full or partial)
coverage determination for the prescription(s)
subject to the edit. Correctly uploads the count, if
the data set of POS rejects includes the complete
reporting period, into HPMS including the following
criteria:
a: From the subset of POS rejects (RSC 6b)
related to the hard MME safety POS edits,

Update

Consistent
with current
technical
guidance

None

CY 2022 DV (2021 Reporting Requirements)

CY 2023 DV (2022 Reporting Requirements)

DUR

RSC-9: The organization accurately identifies the
number of unique beneficiaries with at least one
POS claim rejection related to a hard MME safety
edit and/or opioid naïve days supply safety edit
that also had a claim successfully processed at
POS through a favorable coverage determination
or plan override. Correctly uploads the count, if
the data set of POS rejects includes the complete
reporting period, into HPMS including the
following criteria:

DUR

RSC-9.a. - The organization accurately identifies
the number of unique beneficiaries with at least
one POS claim rejection related to a hard MME
safety edit and/or opioid naïve days supply safety
edit that also had a claim successfully processed
at POS through a favorable coverage
determination or plan override. Correctly uploads
the count, if the data set of POS rejects includes
the complete reporting period, into HPMS
including the following criteria:
a: From the subset of POS rejects (RSC 6b)
related to the hard MME safety POS edits,

Reporting
Section

Type of
Change

Reason for
Change

Burden
Change

RSC-9b The organization accurately identifies the
number of unique beneficiaries with at least one
POS claim rejection related to a hard MME safety
edit and/or opioid naïve days supply safety edit
who had a favorable (either full or partial) coverage
determination for the prescription(s) subject to the
edit. Correctly uploads the count, if the data set of
POS rejects includes the complete reporting
period, into HPMS including the following criteria:
b: From the subset of POS rejects (RSC 6c)
related to the opioid naïve days supply safety POS
edits,

Update

Consistent
with current
technical
guidance

None

RSC-10: The organization accurately identifies the
number of unique beneficiaries with at least one
POS claim rejection related to a hard MME safety
edit and/or opioid naïve days supply safety edit that
was overridden due to an exemption (Elements S,
BB), because the beneficiary was not opioid naïve
(Element CC), or for whom up to a 7-day supply
(covered by the plan) was dispensed by the
pharmacy (Element DD). Correctly uploads the
count, if the data set of POS rejects includes the
complete reporting period, into HPMS, including
the following criteria:

Update

Consistent
with current
technical
guidance

None

CY 2022 DV (2021 Reporting Requirements)

CY 2023 DV (2022 Reporting Requirements)

DUR

RSC-9b The organization accurately identifies the
number of unique beneficiaries with at least one
POS claim rejection related to a hard MME safety
edit and/or opioid naïve days supply safety edit
that also had a claim successfully processed at
POS through a favorable coverage determination
or plan override. Correctly uploads the count, if
the data set of POS rejects includes the complete
reporting period, into HPMS including the
following criteria:
b: From the subset of POS rejects (RSC 6c)
related to the opioid naïve days supply safety POS
edits,

DUR

RSC-10: The organization accurately identifies the
number of unique beneficiaries with at least one
POS claim rejection related to a hard MME safety
edit and/or opioid naïve days supply safety edit
that also had a claim successfully processed at
POS other than through a favorable coverage
determination or appeal such as pharmacist
communication and/or plan override. Correctly
uploads the count, if the data set of POS rejects
includes the complete reporting period, into HPMS
including the following criteria:

Reporting
Section

Type of
Change

Reason for
Change

Burden
Change

RSC-10.a: The organization accurately identifies
the number of unique beneficiaries with at least
one POS claim rejection related to a hard MME
safety edit and/or opioid naïve days supply safety
edit that was overridden due to an exemption
(Elements S, BB), because the beneficiary was not
opioid naïve (Element CC), or for whom up to a 7day supply (covered by the plan) was dispensed by
the pharmacy (Element DD). Correctly uploads the
count, if the data set of POS rejects includes the
complete reporting period, into HPMS, including
the following criteria:

Update

Consistent
with current
technical
guidance

None

RSC-10.b: The organization accurately identifies
the number of unique beneficiaries with at least
one POS claim rejection related to a hard MME
safety edit and/or opioid naïve days supply safety
edit that was overridden due to an exemption
(Elements S, BB), because the beneficiary was not
opioid naïve (Element CC), or for whom up to a 7
day supply (covered by the plan) was dispensed by
the pharmacy (Element DD). Correctly uploads the
count, if the data set of POS rejects includes the
complete reporting period, into HPMS including the
following criteria:
b: From the subset of POS rejects (RSC 6c)
related to the opioid naïve days supply safety POS
edits,

Update

Consistent
with current
technical
guidance

None

CY 2022 DV (2021 Reporting Requirements)

CY 2023 DV (2022 Reporting Requirements)

DUR

RSC-10.a: The organization accurately identifies
the number of unique beneficiaries with at least
one POS claim rejection related to a hard MME
safety edit and/or opioid naïve days supply safety
edit that also had a claim successfully processed
at POS other than through a favorable coverage
determination or appeal such as pharmacist
communication and/or plan override. Correctly
uploads the count, if the data set of POS rejects
includes the complete reporting period, into HPMS
including the following criteria:

DUR

RSC-10.b: The organization accurately identifies
the number of unique beneficiaries with at least
one POS claim rejection related to a hard MME
safety edit and/or opioid naïve days supply safety
edit that also had a claim successfully processed
at POS other than through a favorable coverage
determination such as pharmacist communication
and/or plan override. Correctly uploads the count,
if the data set of POS rejects includes the
complete reporting period, into HPMS including
the following criteria:
b: From the subset of POS rejects (RSC 6c)
related to the opioid naïve days supply safety POS
edits,


File Typeapplication/pdf
File TitleCY 2022 to CY 2023 Data Validation Appendix J 60-Day Comment Period Crosswalk of Changes
Subjectdata validation; reporting requirements; Medicare Part C; Medicare Part D
AuthorCenters for Medicare and Medicaid Services
File Modified2022-07-15
File Created2022-07-15

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