Non-Substantive Justification Memo

To: Jamie Wilson

Office of Information and Regulatory Affairs (OIRA)

Office of Management and Budget (OMB)

From: William Parham

Office of Strategic and Regulatory Affairs

PRA Staff

Date: October 4, 2024

Subject: Non-Substantive Change Request – Medicare Part C Reporting Requirements (OMB# 0938-1054)

This memo requests approval of non-substantive changes to the approved information collection, Medicare Part C Reporting Requirements (OMB# 0938-1054)

Background

The collection of additional data elements related to supplemental benefits cost and utilization among plan enrollees, with an effective date of January 1, 2024. CMS is adding this section in accordance with recommendations from members of the United States Congress,1 the Medicare Payment Advisory Commission (MedPAC), Government Accountability Office (GAO), and other industry stakeholders. These elements also align with and expand upon the new MLR reporting requirements (87 FR 27704) on supplemental benefits, as well as the more limited information submitted in the Plan Benefit Package (PBP) categories and subcategories. This information will improve CMS’s understanding of the accessibility and utilization of supplemental benefits by Medicare Advantage enrollees.

The collection was last approved by OMB on December 29, 2023 and expires on December 31, 2025.

Overview of Requested Changes

Subsequent to OMB’s approval on December 29, 2023, the Centers for Medicare and Medicaid Services (CMS) needs to clarify the Plan Benefit Package (PBP) categories (to be consistent with the Health Plan Management System) to align with the official list of benefits as recorded by plans in their annual PBP software submission. This non-material/non-substantive change request is to implement these minor changes and replace the current CY 2024 Part C Reporting Requirements and CY 2024 Part C Technical Specifications with the updated version. There are no other changes being made at this time and there are no program changes or burden adjustments.