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Aug 4 -- The Centers for Medicare & Medicaid Services (CMS) invite comment to OMB by September 6, 2022 regarding Medicare Part C and Part D Data Validation.  

Sections 1857(e) and 1860D-12 of the Social Security Act (“the Act”) authorize CMS to establish information collection requirements with respect to MAOs and Part D sponsors. Section 1857(e)(1) of the Act requires MAOs to provide the Secretary of the Department of Health and Human Services (DHHS) with such information as the Secretary may find necessary and appropriate. Section 1857(e)(1) of the Act applies to Prescription Drug Plans (PDPs) as indicated in section1860D-12. Pursuant to statutory authority, CMS codified these information collection requirements in regulation at §§ 422.516(g) Validation of Part C Reporting Requirements, and 423.514(j) Validation of Part D Reporting Requirements respectively.

Data collected via Medicare Part C and Part D reporting requirements are an integral resource for oversight, monitoring, compliance and auditing activities necessary to ensure quality provision of Medicare benefits to beneficiaries. CMS uses the findings collected through the data validation process to substantiate the data reported via Medicare Part C and Part D reporting requirements. Data validation provides CMS with assurance that plan-reported data are credible and consistently collected and reported by Part C and D SOs. CMS uses validated data to respond to inquiries from Congress, oversight agencies, and the public about Part C and D SOs. The validated data also allows CMS to effectively monitor and compare the performance of SOs over time. Validated plan-reported data may be used for Star Ratings, Display measures and other performance measures. Additionally, SOs can take advantage of the DV process to effectively assess their own performance and make improvements to their internal operations and reporting processes.

In order for the reported data to be useful for monitoring and performance measurement, the data must be reliable, valid, complete, and comparable among sponsoring organizations (SOs). To maintain the independence of the validation process, sponsoring organizations do not use their own staff to conduct the data validation process. SOs are responsible for hiring external, independent data validation contractors (DVCs) who meet a minimum set of qualifications and credentials, which CMS outlines in the “Standards for Selecting Data Validation Contractors” document. For the retrospective review in 2023, the DVCs will review data submitted by SOs for contract year (CY) 2022.

CMS developed standards and data validation criteria for specific Medicare Part C and Part D reporting requirements that the DVCs use in validating the SOs’ data. The standards are listed in Appendix J. The data validation standards for each reporting section include standard instructions relevant to the type of information that should be reviewed, and the reporting section-specific criteria (RSC) that are aligned with the Medicare Part C and Part D Reporting Requirements. The standards and criteria describe how the DVCs should validate the SOs’ compilations of reported data, considering appropriate data exclusions, and verifying calculations, source code, and algorithms. The data validation reviews are conducted at the contract level given that the Medicare Part C and Part D data are generally available at the contract level, and the contract is the basis of any legal and accountability issues concerning the rendering of services.

The review is conducted over a three-month period (April – June) following the final submission of data by the SOs. The DVCs employ a set of information guides and collection tools when performing their reviews. The Organizational Assessment Instrument (Appendix B) is completed by the SO prior to the review and is shared with the DVCs. The tool used to record the results of the data validation is the “Findings Data Collection Form” (FDCF). The FDCF, displayed in Appendix J, allows contractors to record notes, reference data sources, and capture findings for the different standards and criteria specified for a given reporting section. The DVC submits the completed FDCF to CMS via the Health Plan Management System (HPMS).

Part C and Part D Data Validation: https://www.cms.gov/Medicare/Prescription-Drug-Coverage/PrescriptionDrugCovContra/PartCDDataValidation
Submission to OMB: https://www.reginfo.gov/public/do/PRAViewICR?ref_nbr=202208-0938-008 Click on IC List for collection instruments, View Supporting Statement for technical documentation. Submit comments through this site.
FR notice inviting public comment: https://www.federalregister.gov/d/2022-16682
For AEA members wishing to submit comments, "A Primer on How to Respond to Calls for Comment on Federal Data Collections" is available at https://www.aeaweb.org/content/file?id=5806

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