60-Day Crosswalk

2024 Approved Document	2025 60-Day Document	Type of Change	Reason for Change	Burden Change
Medicare-Medicaid Plans (MMP) removed from applicable organziation types required to report Part C reporting requirements.	Deleted	Update	The MMP plan type is terminating at the end of CY 2025, as CMS transitions the FAI demonstrations to D-SNP models.	Decrease
Supplemental Benefits Reporting Section-CY 2025 PBP service categories	Updated throughout the reporting section to accurately represent the CY 2025 PBP service categories and titles.	Update	The CY 2025 PBP categories are updated to reflect additional services and recategorizations, including dental and OTC hearing services.	Increase
Supplemental Benefits Reporting Section-Service Area-Related Services	Removed the visitor/travel program and out-of-network categories to include as reported PBP elements. These elements are now provided as new data elements provided by the plan.	Update	This change will allow CMS to more accurately see how the benefits are being offered and utilized based on their network status.	Increase
Supplemental Benefits Reporting Section-Data element ID and data element description	Added Contract ID and PBP ID as two data elements that must be included. Subsequent renumbering throughout the chart as a result.	New	Clarification	Increase
Supplemental Benefits Reporting Section-Data element ID and data element description	Supplemental Benefits Reporting Section - Element F- network type (in-network, out-of-network (for PPO), out-of-network (for HMO-POS), and visitor/travel)	Update	Removed as part of the PBP elements, and now must be reported separately.	Increase
Supplemental Benefits Reporting Section-Data element ID and data element description	Supplemental Benefits Reporting Section - Element N -The total out-of-pocket cost for enrollees.	New	New Part C Reporting Requirement to clarify that plan cost sharing may vary depending on the type of supplemental benefit.	Increase
Supplemental Benefits Reporting Section-Data element ID and data element description	Supplemental Benefits Reporting Section - Element O - The median out-of-pocket cost for enrollees.	New	New Part C Reporting Requirement to clarify that plan cost sharing may vary depending on the type of supplemental benefit.	Increase
None	D-SNP Enrollee Advisory Committee	New	New Part C Reporting Requirement	Increase
Updated: February 2024	Updated: January 2025	Update	Year changed to reflect updates being made to current version.	None
None	D-SNP Transmission of Admission Notifications	New	New Part C Reporting Requirement	Increase
None	Addition of Withdrawn Grievances to Do Not Report section	New	Clarification	None
Organization Determination is a plan’s response to a request for coverage (payment or provision) of an item, service, or Part B drug, including auto-adjudicated claims, service authorizations which include prior-authorization (authorization that is issued prior to the services being rendered), concurrent authorization (authorization that is issued at the time the service is being rendered), post authorization (authorization that is issued after the service has been rendered), and requests to continue previously authorized ongoing courses of treatment. It includes pre-service organization determination requests submitted by the enrollee, enrollee’s representative, contract provider on behalf of the enrollee and requests from non-contract providers. It does not include claims payment requests from contract providers that are governed by the contractual arrangement between the MAO and its contract providers	Addition of : "Applicable integrated plans report integrated organization determinations per 42 CFR § 422.631."	Update	Clarification	None
Reconsideration is a plan’s review of an adverse or partially favorable organization determination as defined in 42 CFR § 422.580	Addition of: "Applicable integrated plans report integrated reconsiderations per 42 CFR § 422.633."	Update	Clarification	None
Do Not Report: Data from Medicare/Medicaid Programs (MMPs) organizations	Deleted	Update	The MMP plan type is terminating at the end of CY 2025, as CMS transitions the FAI demonstrations to D-SNP models.	None
HRA Reporting Timline: There are situations when a new enrollee who has remained enrolled in the SNP for 365 days after the date of the initial HRA, will be counted in both data elements A and B. because the he/she is a new enrollee (A) and an enrollee eligible for an annual reassessment (B).	There are situations when a new enrollee who has remained enrolled in the SNP for 365 days after the date of the initial HRA, will be counted in both data elements A and B. because the individual is a new enrollee (A) and an enrollee eligible for an annual reassessment (B).	Update	Clarification	None
Enrollees who were previously in a Medicare-Medicaid Plan and received an initial or annual HRA that were cross walked to a D-SNP within the MAO after the end of a Financial Alignment Demonstration will not need to participate in a second initial HRA. They should be included in element B.	Enrollees who were previously in a Medicare-Medicaid Plan and received an initial or annual HRA that were cross walked to a D-SNP within the MAO after the end of a Financial Alignment Initiative demonstration will not need to participate in a second initial HRA. They should be included in element B.	Update	Clarification	None
If eligibility records received after completion of the HRA indicate the member was never enrolled in the plan, do not count this member as a new  enrollee and do not count the HRA	If eligibility records received after completion of the HRA indicate the individual was never enrolled in the plan, do not count this individual as a new  enrollee and do not count the HRA	Update	Clarification	None
For Dual Eligible SNPs (D-SNPs) only, CMS will accept a Medicaid HRA that is performed by the same organization (or an affiliate under the same parent orzation) within 90 days before or after the effective date of Medicare enrollment as meeting the Part C obligation to perform an HRA.	For dual eligible SNPs (D-SNPs) only, CMS will accept a Medicaid HRA that is performed by the same organization (or an affiliate under the same parent orgnization) within 90 days before or after the effective date of Medicare enrollment as meeting the Part C obligation to perform an HRA, if the HRA meets the requirements at 42 CFR § 422.101(f).	Update	Clarification	None
Questions have arisen regarding how to report data elements in this reporting section when enrollees disenroll and then re-enroll, either in the same SNP or a different one (different organization or sponsor) within the measurement year. When a member disenrolls from one SNP and enrolls into another SNP (a different sponsor or organization), the member should be counted as a “new enrollee” for the receiving plan.	Questions have arisen regarding how to report data elements in this reporting section when enrollees disenroll and then re-enroll, either in the same SNP or a different one (different organization or sponsor) within the measurement year. When an individual disenrolls from one SNP and enrolls into another SNP (a different sponsor or organization), the individual should be counted as a “new enrollee” for the receiving plan.	Update	Clarification	None
When a member enrolls, disenrolls, and re-enrolls, into any SNP under the same contract number, the previous HRA is still considered valid and can continue to be used as long as it is not more than 365 days old. Even if the member is re-enrolling into the same plan, the individual would still not be counted more than once in any category.	When an individual enrolls, disenrolls, and re-enrolls, into any SNP under the same contract number, the previous HRA is still considered valid and can continue to be used as long as it is not more than 365 days old. Even if the individual is re-enrolling into the same plan, the individual would still not be counted more than once in any category.	Update	Clarification	None
As noted in the table for Element ID A, column “inclusions,” SNPs should include members who disenrolled from and re-enrolled into the same plan if an initial HRA was not performed prior to disenrollment. When this occurs, SNPs should calculate the member's eligibility date starting from the date of re-enrollment.	As noted in the table for Element ID A, column "inclusions," SNPs should include individuals who disenrolled from and re-enrolled into the same plan if an initial HRA was not performed prior to disenrollment. When this occurs, SNPs should calculate the member's eligibility date starting from the date of re-enrollment.	Update	Clarification	none
HHS developed the four categories of value-based payments: fee-for-service with no link to quality (category 1); fee-for-service with a link to quality (category 2); alternative payment models built on fee-for-service architecture (category 3); and population-based payment (category 4).	HHS developed the four categories of value-based payments: fee-for-service with no link to quality (category 1); fee-for-service with a link to quality (category 2); alternative payment models built on fee-for-service architecture (category 3); and population-based payment (category 4). These groupings conform to the Health Care Payment Learning & Action Network (HCPLAN) Alternative Payment Models (APM) Framework categories. For more detailed information, please refer to the LAN APM Framework (https://hcp-lan.org/apm-framework/).	Update	Clarification	None
Category four includes population-based payment arrangements to include some payment is not directly triggered by service delivery so volume is not linked to payment. Under these arrangements, clinicians and organizations are paid and responsible for the care of a beneficiary for a long period (e.g., greater than a year). For detailed information regarding these categories, please refer to the Alternative Payment Model (APM) Framework: https://hcp-lan.org/apm-refresh-white-paper/.	Category four includes population-based payment arrangements to include some payment is not directly triggered by service delivery so volume is not linked to payment. Under these arrangements, clinicians and organizations . responsible for the care of a beneficiary for a long period (e.g., greater than a year).	Update	Clarification	None
None	CMS will also collect data on the number of lives MA organizations have attributed, aligned, assigned, empaneled, or otherwise associated with accountable care arrangements. Under such arrangements providers have accountability for quality and total cost of care for a period of at least six months (i.e. a longitudinal, aligned care relationship between the beneficiary and clinician/provider). For additional detail on the definition of these concepts, please see LAN Guidance on Measuring Covered Lives in Accountable Care APM Arrangements and APM Data Collection Tool found here (https://hcp-lan.org/data-collection-process/#1601909304600-3b650088-e3e1).	New	New Part C Reporting Requirement	Increase
01- Local CCP 04 - PFFS 05 - MMP 11- Regional CCP 15 - RFB Local CCP	01 - Local CCP 04- PFF 11-Regional CCP 15 - RFB Local CCP removed 05-MMP from chart	Update	The MMP plan type is terminating at the end of CY 2025, as CMS transitions the FAI demonstrations to D-SNP models.	None
HHS developed the four categories of value-based payments: fee-for-service with no link to quality (category 1); fee-for-service with a link to quality (category 2); alternative payment models built on fee-for-service architecture (category 3); and population-based payment (category 4).	HHS developed the four categories of value-based payments: fee-for-service with no link to quality (category 1); fee-for-service with a link to quality (category 2); alternative payment models built on fee-for-service architecture (category 3); and population-based payment (category 4). These groupings conform to the Health Care Payment Learning & Action Network (HCPLAN) Alternative Payment Models (APM) Framework categories. For more detailed information, please refer to the LAN APM Framework (https://hcp-lan.org/apm-framework/).	Update	Clarification	none
None	For additional details on the definitions in this section, please see Appendix 2: Measuring Covered Lives in Accountable Care		New Part C Reporting Requirement	Increase
Total dollars paid to providers (in and out of network) for Medicare Advantage enrollees   in [CY 20XX] or most recent 12 months. Total Medicare Advantage payment made to contracted providers	Total dollars paid to providers (in and out of network) for Medicare Advantage membersenrollees   in [CY 20XX] or most recent 12 months.	Update	Clarification/consistency	none
Total dollars paid to providers through legacy payments (including fee-for-service (i.e., payments made for units of service) in [CY 20XX] or most recent 12 months that are adjusted to account for neither infrastructure investments, nor provider reporting of quality data, nor provider performance on cost and quality metrics). ,Also includes diagnosis-related groups that are not linked to quality and value, or capitation without quality components  ) in [CY 20XX] or most recent 12 months.Total Medicare Advantage payment made on a fee-for-service basis with no link to quality (category 1)	Total dollars paid to providers through legacy payments (including fee-for-service (i.e., payments made for units of service) in [CY 20XX] or most recent 12 months that are adjusted to account for neither infrastructure investments, nor provider reporting of quality data, nor provider performance on cost and quality metrics). Also includes diagnosis-related groups that are not linked to quality and value in [CY 20XX] or most recent 12 months.	Update	Clarification/consistency	none
Total dollars paid to providers through fee-for-Service plus pay-for-performance payments (linked to quality) in [CY 20XX] or most recent 12 months.Total Medicare Advantage payment made on a fee-for-service basis with a link to quality (category 2)	Total dollars paid to providers through fee-for-Service plus pay-for-performance payments (linked to quality) in [CY 20XX] or most recent 12 months.	update	Clarification/consistency	none
F. Total dollars paid to providers through traditional shared-savings (linked to quality) payments in [CY 20XX] or most recent 12 months.Total Medicare Advantage payment made using alternative payment models built on fee-for-service architecture (category 3)	D. Total dollars paid to providers through traditional shared-savings (linked to quality) payments in [CY 20XX] or most recent 12 months.	Update	Clarification/consistency	none
E. Total Risk-based payments not linked to quality (e.g., 3N in APM definitional framework)	K. Total Risk-based payments not linked to quality (e.g., 3N in APM definitional framework)	Update	consistency	none
L. Total dollars paid to providers through condition-specific, population-based payments (linked to quality) in [CY 20XX] or most recent 12 months.Total Medicare Advantage payment made using population-based payment (category 4)	F. Total dollars paid to providers through condition-specific, population-based payments (linked to quality) in [CY 20XX] or most recent 12 months.Total Medicare Advantage payment made using population-based payment (category 4)	Update	consistency	none
H. Total number of Medicare Advantage contracted providers	S. Total number of Medicare Advantage contracted providers	Update	consistency	none
I. Total Medicare Advantage contracted providers paid on a fee-for-service basis with no link to quality (category 1)	T. Total Medicare Advantage contracted providers paid on a fee-for-service basis with no link to quality (category 1)	Update	consistency	none
J. Total Medicare Advantage contracted providers paid on a fee-for-service basis with a link to quality (category 2)	U. Total Medicare Advantage contracted providers paid on a fee-for-service basis with a link to quality (category 2)	Update	consistency	none
K. Total Medicare Advantage contracted providers paid based on alternative payment models built on a fee-for-service architecture (category 3)	V. Total Medicare Advantage contracted providers paid based on alternative payment models built on a fee-for-service architecture (category 3)	Update	consistency	none
L. Total Medicare Advantage contracted providers paid based risk-based payments not linked to quality (e.g., 3N in the APM definitional framework)	Z. Total Medicare Advantage contracted providers paid based risk-based payments not linked to quality (e.g., 3N in the APM definitional framework)	Update	consistency	none
N. Total Medicare Advantage contracted providers paid based on capitation with no link to quality (e.g., category 4N in the APM definitional framework)	FF. Total Medicare Advantage contracted providers paid based on capitation with no link to quality (e.g., category 4N in the APM definitional framework)	Update	consistency	none
PCP/PCG-Focused Accountable Care Metrics (metrics below apply to the number of MA plan members in an accountable care arrangements. Metrics are linked to quality)	PCP/PCG-Focused Accountable Care Metrics (metrics below apply to the number of MA plan enrollees in an accountable care arrangements. Metrics are linked to quality)	Update	consistency	none
Total number of Medicare Advantage health plan members attributed/aligned/assigned/empaneled to a Primary Care Provider (PCP) or Primary Care Group (PCG) participating in a TCOC Category 3 or 4 accountable care APM of six months or longer in [CY 20XX] or most recent 12 months. [This does NOT include health plan enrollees members attributed/aligned/assigned/empaneled to a PCP or PCG, who are paid based on capitation with no link to quality (4N)].	Total number of Medicare Advantage health plan enrollees attributed/aligned/assigned/empaneled to a Primary Care Provider (PCP) or Primary Care Group (PCG) participating in a TCOC Category 3 or 4 accountable care APM of six months or longer in [CY 20XX] or most recent 12 months. [This does NOT include health plan enrollees attributed/aligned/assigned/empaneled to a PCP or PCG, who are paid based on capitation with no link to quality (4N)]	Update	clarification	none
Non-PCP/PCG-Focused Accountable Care Metric (metrics below apply to the number of MA plan members in an accountable care arrangements. Metrics are linked to quality)	Non-PCP/PCG-Focused Accountable Care Metric (metrics below apply to the number of MA plan enrollees in an accountable care arrangements. Metrics are linked to quality)	Update	consistency	none
Total number of Medicare Advantage health plan members attributed/aligned/assigned/empaneled to non-PCPs (i.e., specialists) participating in a TCOC Category 3 or 4 accountable care APM (e.g., shared savings with upside risk only) of six months or longer in [CY 20XX] or most recent 12 months. [This does NOT include health plan members attributed/aligned/assigned/empaneled to a non-PCP/PCG provider, who are paid based on capitation with no link to quality (4N)].	Total number of Medicare Advantage health plan enrollees attributed/aligned/assigned/empaneled to non-PCPs (i.e., specialists) participating in a TCOC Category 3 or 4 accountable care APM (e.g., shared savings with upside risk only) of six months or longer in [CY 20XX] or most recent 12 months. [This does NOT include health plan enrollees attributed/aligned/assigned/empaneled to a non-PCP/PCG provider, who are paid based on capitation with no link to quality (4N)].	Update	consistency	none
Fee-for-service with no link to quality (category 1); Feefor-service with a link to quality (category 2); Alternative payment models built on fee- for- service architecture (category 3); Population-based payment (category 4) For additional guidance regarding the four (4) categories of payment, we ask that you refer to the Learning Action Network Definitional.	Fee-for-service with no link to quality (category 1); Fee- for-service with a link to quality (category 2); Alternative payment models built on fee- for- service architecture (category 3); Population-based payment (category 4) For additional guidance regarding the four (4) categories of payment, we ask that you refer to the Learning Action Network Definitional Framework white paper.	correction	accuracy	none
For data elements F – J, how do we report if a provider is paid using multiple payment arrangements that fit under multiple categories?	For data elements S – FF, how do we report if a provider is paid using multiple payment arrangements that fit under multiple categories?	update	consistency	none
For data elements F and J are we to report by individual providers or by contracts (which include groups with one or more providers)	For data elements S. and FF. are we to report by individual providers or by contracts (which include groups with one or more providers)?	Update	consistency	none
For data elements A – E, are we to report payments made to providers in 2024 based on services rendered in 2023?	For data elements A. – R., are we to report payments made to providers in 20XX based on services rendered in the prior year?	Update	consistency	none
For data elements A – E, do payments refer to the total calculated allowed amount or actual payments to providers?	For data elements A. – R., do payments refer to the total calculated allowed amount or actual payments to providers?	Update	consistency	none
Supplemental benefits reporting section, PBP categories and Supplemental Benefit names updated	Several PBP categories and supplemental benefit category names have been updated to match what the PBP in HPMS lists for these benefits (e.g. 1a2 Inpatient Acute Non-Medicare Covered Stay is now 1a2 Non-Medicare covered Stay for Inpatient Hospital-Acute)	Update	Accuracy, the PBP categories and Supplemental Benefit names are being updated to match the PBP submissions in HPMS	none
Supplemental benefits reporting section, headers updated	The headers have been updated to match the PBP submission in HPMS	New	Accuracy	increase
Supplemental benefits reporting section, Dental categories	These categories have been updated to match the new dental categories in the HPMS submission for the PBP	New	New Part C Reporting Requirement, Accuracy	increase
Section V. Enrollment and Disenrollment	Updated reference to Enrollment/Disenrollment guidance, added URL	Update	accuracy	None
Tech Specs: Section III. Enrollment and Disenrollment	Updated reference to Enrollment/Disenrollment guidance, added URL	Update	accuracy	None
Payments to Providers- Data element W added	Missing data element added on 9.27	Update	New Part C Reporting Requirement	Increase
Payments to Providers- Data element CC added	Missing data element added on 9.27	Update	New Part C Reporting Requirement	Increase
FAQ- new FAQ questions added for the payments to providers section.	11 new FAQ questions added to provide definitions and clarifications.	Update	clarification	None