Beacon Compliance Hot Topics: August 2019


Medicare Parts C and D Reporting Requirements – Data Validation 30-Day Comment Period

An HPMS memo titled “Medicare Parts C and D Reporting Requirements – Data Validation 30-day Comment Period” was issued on August 22, 2019. CMS is providing an opportunity for Medicare Advantage Organizations, Part D sponsors, and other stakeholders to comment on the proposed Medicare Part C and Part D Data Validation of Reporting Requirements data for the 2020 collection period. The comments are due by September 16, 2019.


The Centers for Medicare and Medicaid Services (CMS) established reporting requirements for Medicare Part C and Part D sponsoring organizations. Under these reporting requirements, each sponsoring organization must submit Medicare Part C, Medicare Part D, or Medicare Part C and Part D data each year at various intervals. CMS has stated that for the reporting data to be useful for monitoring and performance measurement, the data must be reliable, valid, complete, and comparable among sponsoring organizations. To maintain the independence of the validation process, sponsoring organizations are responsible for hiring external, independent data validation contractors (DVCs) who meet a minimum set of qualifications and credentials.

For the retrospective review in 2020, the DVCs will review data submitted by sponsoring organizations for CY2019 and will follow standardized requirements. 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 main changes for the 2020 data validation documents were made to the Part C and Part D Reporting Section Data Validation Standards (Appendix B), and the Findings Data Collection Form (Appendix J), specifically for the Medication Therapy Management (MTM) Programs, Coverage Determinations and Redeterminations (CD/RD), and Improving Drug Utilization Review Controls (DUR) reporting sections. The updates are consistent with the approved 2019 Part D Technical Specifications and Reporting Requirements and submission process.

The changes to the aforementioned documents as part of the CY 2020 Data Validation Process are listed below and are identified in bold, per reporting section:

1. MTM Report Section:

a. If a Comprehensive Medication Review (CMR) was not received, there are no reported delivery date(s) unless the CMS summary was returned via mail, then the reported delivery date should be the date that the written summary was sent.

b. The MTM upload must be completed via HPMS instead of Gentran

2. CD/RD Report Section:

a. Changes in element numbers

b. Date of each reopening disposition is equal to or later than the date of original disposition.

c. Exclude requests for coverage determinations (including exceptions) that are withdrawn or dismissed.

d. Excludes requests for exceptions that are withdrawn or dismissed.

e. Excludes dismissals and withdrawals

3. DUR Report Sections:

a. Count elements by plan level instead of contract level.

Recommended Action

1. Share documents with impacted operational areas.

2. Review changes and determine if any action is required to current organizational processes, inclusive of data collection and storage, and written policies and/or procedures.

3. Submit comments by September 16, 2019:

a. Email.

b. By regular mail. You may mail written comments to the following address:

c. Fax. (202) 395-5806

d. Reference the document identifier or OMB Control number.

i. Document identifier: CMS-10305

ii. OMB Control number: 0938-1115