Crosswalk (60day-30day)

Crosswalk -CMS-10905.xlsx

Service Level Data Collection for Initial Determinations and Appeals (CMS-10905)

Crosswalk (60day-30day)

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60-day Package Revised/New in 30-day Package Reason for Change
There were two reporting sections with no subsections- Initial Determinations and Appeals There are now two subsections for each reporting section -
Initial Determinations (coverage decisions), Initial Determinations (payment), Reconsiderations (coverage decisions), Reconsiderations (payment)
Previously, there were elements that only applied to either a coverage request or a payment request and this could have been confusing to report. This change was also in response to comments related to whether the reporting applies to both pre-service and payment requests. By separating each section this clarifies the expectation for reporting of both pre-service/coverage and payment requests.
Reporting Elements for all Initial Determination Requests:

OD Number
Contract number and PBP
Parent organization
Provider NPI
Enrollee MBI
Requested service codes (CPT/HCPCS)
Name of service associated with CPT/HCPCS
Submitted diagnosis codes (e.g., ICD-10, HIPPS codes)
Processing priority (standard or expedited)
Service location (Zip)
Date of service
Provider status (contracted or non-contracted)
Approved or denied
Date request received
Date of decision
Decision rationale
Were internal plan criteria applied?
Was PA requested?
If element R is yes, provide OD number for PA (claims only)
If element R is yes, was PA request required?
If element R is yes, was a voluntary pre-service request received?
Place of service, if applicable https://www.cms.gov/medicare/coding-billing/place-of-service-codes/code-sets
Revised Reporting Elements for Initial Determinations (coverage decisions):

Organization Determination Number
Contract Number
Plan Benefit Package (PBP)
Enrollee MBI
Requesting Party
Provider NPI
Item/Service/Part B Drug Code
Item/Service/Part B Drug Description
Diagnosis Codes
Was prior authorization required?
Was this a concurrent review decision?
Processing Priority
Was expedited processing requested?
Date Request Received
Date of Decision Notification
Disposition
Dismissal Rationale (if applicable)
Decision Rationale
Reviewer Qualifications
Were internal plan coverage criteria applied?
Did a third-party vendor participate, in any capacity, in the determination’s review or decision-making?
Based on comments and upon further review, there have been several revisions to the elements.  We have reworded/rephrased some elements to improve clarity and the addition of new elements in each reporting section will allow CMS to broaden the scope of review for each case. Many commenters requested clarification around what is a "voluntary pre-service request".  As a result, we revised this element to avoid confusion and will gather the information needed by asking if prior-authorization was required. We have also added "reviewer qualification" at the initial determination level based on several comments received. 
Revised Reporting Elements for Initial Determinations (payment):

Organization Determination Number
Contract Number
Plan Benefit Package (PBP)
Enrollee MBI
Requesting Party
Item/Service/Part B Drug Code
Item/Service/Part B Drug Description
Diagnosis Codes
Service Location
Place of Service
Date of Service
Provider NPI
Date Claim Received
Date of Decision
Date Claim was Paid
Was it a clean claim?
Disposition
Dismissal Rationale (if applicable)
Decision Rationale
Reviewer Qualifications
Were internal plan coverage criteria applied?
Was prior approval (e.g., a prior authorization or voluntary pre-service request) requested?
If element V is yes, provide the organization determination number for associated prior approval request
If element V is yes, was prior authorization a required condition for coverage?
Did a third-party vendor participate, in any capacity, in the determination’s review or decision-making?

Reporting Elements for Reconsiderations:

Applicable initial determination number (to link to initial decision)
Approved/denied
Date request received
Date of decision
Processing priority (standard or expedited)
Decision rationale
Reviewer qualifications
Revised Elements for Reconsiderations (coverage decisions):

Associated Organization Determination Number
Appeal Number
Contract Number
Plan Benefit Package (PBP)
Enrollee MBI
Date Request Received
Date of Decision Notification
Processing Priority
Was expedited processing requested?
Is this an appeal of an organization determination dismissal?
Disposition
Dismissal Rationale (if applicable)
Decision Rationale
Was the initial organization determination request denied for lack of medical necessity?
Was the reconsideration request reviewed by a physician?
Did a third-party vendor participate, in any capacity, in the determination’s review or decision-making?

Revised Elements for Reconsiderations (payment):

Associated Organization Determination Number
Appeal Number
Contract Number
Plan Benefit Package (PBP)
Enrollee MBI
Date Request Received
Date of Decision Notification
Date Claim was Paid
Is this an appeal of an organization determination dismissal?
Disposition
Dismissal Rationale (if applicable)
Decision Rationale
Was the initial organization determination request denied for lack of medical necessity?
Was the reconsideration request reviewed by a physician?
Did a third-party vendor participate, in any capacity, in the determination’s review or decision-making?

Background read:
"The Part C Reporting Requirements, as set forth in § 422.516(a), provide CMS with the ability to collect more granular data related to all plan activities regarding adjudicating requests for coverage and plan procedures related to making service utilization decisions. This includes collecting more timely data with greater frequency or closer in real-time. Pursuant to that authority, each MAO must have an effective procedure to develop, compile, evaluate, and report information to CMS in the time and manner that CMS requires."
Revised to read:
"The Part C Reporting Requirements, as set forth in 42 CFR § 422.516(a), provide CMS with the ability to collect data on plan procedures related to, and utilization of, its items and services. This includes collecting service-level data related to plan coverage and appeal decisions that are processed in accordance with the requirements of part 422, subpart M. Pursuant to that authority, each MAO must have an effective procedure to develop, compile, evaluate, and report information to CMS in the time and manner that CMS requires."
The revised language is more clear and concise as it relates to the intent and general expectation of the data collection.

Included due dates for each quarterly submission To ensure plans are aware of CMS' expectation for timely submission of the data.
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