Response to Comment Document

CMS Response to Public Comments Received for CMS-10340
The Centers for Medicare and Medicaid Services (CMS) received comments from a
Medicare Advantage organization (MAO) and an Association related to CMS-10340.
This is the reconciliation of the comments.
Comment:
The Centers for Medicare and Medicaid Services (CMS) received one comment from an
MAO. The MAO’s comments were unrelated to the PRA package and described a
specific plan issue with editing and requested clarification surrounding certain policies
and processes. Specifically, the commenter reported challenges submitting delete
transactions related to the 98320 duplicate edit and provided a suggestion for
consideration. The commenter also requested clarification on the submission of unlinked
CRRs. The commenter asked when CMS would establish new performance measures and
thresholds for encounter data. The comments did not suggest changes to the Collection of
Encounter Data from MA Organizations, Section 1876 Cost HMOs/CMPs, MMPs, and
PACE Organizations.
Response:
CMS appreciates the suggestion for the editing logic, the request for clarification on
unlinked CRRs, and the inquiry on when CMS will establish new performance measures
and thresholds for encounter data, although the comments are not the focus of this
collection. CMS shall take under advisement the recommendation put forth from this
MAO regarding editing logic and should further consultation be required on the other
topics, CMS shall contact the commenter.
Comment:
The Centers for Medicare and Medicaid Services (CMS) received one comment from an
Association. The Association’s comment was unrelated to the PRA package, and instead
was a request to update Chapter 7 of the Medicare Managed Care Manual on Risk
Adjustment with a public comment period. Specifically, the commenter recommended
specific updates be made to the chapter to reflect recent risk adjustment model revisions,
updates to include information about encounter data, as well as updates to related risk
adjustment and risk score calculation information. The comments did not suggest changes
to the Collection of Encounter Data from MA Organizations, Section 1876 Cost
HMOs/CMPs, MMPs, and PACE Organizations.
Response:
CMS appreciates the request to update Chapter 7 on Risk Adjustment and shall take the
recommendation under advisement, although the comments are not the focus of this
collection.