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Medicare Advantage Quality Measurement & Performance Assessment Conference
April 8, 2008
Medicare Part D Reporting Requirements
Alice Lee-Martin, PharmDDivision of Clinical and Economic Performance
Medicare Drug Benefit Group
Objectives
Discuss purpose of Part D Reporting Requirements, and CY2008 changes
Outline CMS’ compliance actions related to reporting
Discuss CY2009 reporting requirements
Purpose of Reporting Requirements
Plan reported data – provides more timely information than other
sources– updates Plan information – provides long-term monitoring and oversight of
the Medicare Drug Benefit
New areas added to reflect policy changes
Changes to CY2007 Reporting Sections
Transition
Medication Therapy Management (MTM) Programs
Long-term Care (LTC) Rebates
Drug Benefit Analysis
Transition
Revised from CY2007 to collect more specific information about Plans’ safeguards in both retail and LTC settings
Reporting frequency changed to annual submission of 1st quarter data
MTM Programs
Evaluation of MTMP outcomes requires non-aggregate MTM data
Information about MTM-eligible beneficiaries, including LTC enrollment
Period of MTMP participation If applicable, reason for MTMP discontinuation
Elements also added for comprehensive reporting of MTM participants# of beneficiaries discontinuing for other reason For Period 1, # of beneficiaries pending
Long-term Care (LTC) Rebates
Potential UM conflicts may be specific to drug formulation– Report NDC and drug name
Special reporting cases:Exemption for LTC pharmacies that serve less
than 5% of LTC beds in an area Non-compliant LTC pharmacy
Drug Benefit Analyses
Comprehensive representation of Plan’s enrollment– Include LIS and non-LIS members – Enrollees in all benefit phases, including the
deductible phase
More timely submission of reports to CMS– Monthly instead of quarterly
New Reporting Sections for CY2008
Retail, Home Infusion, and Long-Term Care Pharmacy Access
Access to Extended Day Supplies at Retail Pharmacies
Vaccines
Retail, HI and LTC Pharmacy Access
Updates information from Plans’ initial Part D applications
Confirms pharmacy access standards continue to be met
Retail access figures Contracted HI and LTC network pharmacies Additional data from plans receiving waivers
– any willing pharmacy requirement– retail pharmacy convenient access standards
Access to Extended Day Supplies at Retail Pharmacies
Reported only by Part D Plans with mail-order pharmacies offering extended day supplies of covered Part D drugs
Verifies reasonable access to the same extended day supply benefits at retail
Reported annually
Vaccines
Statutory shift of Part D vaccine administration from Part B to Part D in 2008
Monitors methods to facilitate vaccine administration
Data reported quarterly by Contact: Total # of Part D vaccines processed # of vaccines
administered in a clinic setting adjudicated through network pharmacies processed through a paper enhanced process processed through an internet based web tool via other processing method
Other Changes
Call Center and Reversal reporting sections removed
Generic Drug Utilization (Generic Drug Rate)
Other clarifications Language, terminologyData elements Field formats
Beyond CY2008
CY2008 Reporting requirements will remain in effect for CY2009
Additional areas and changes for future contract year requirements
Technical specifications – Spring 2008– Data element definitions– Validation and QA thresholds– Analyses– Other clarifications, e.g. FAQ
Analysis and Reporting
Initial QA by CMS: Missing data submissionsStatistical tests for outliersData entry errors
Frequent resubmissions, failure to resubmit data flagged Sponsors contacted if identified as outliers
Review and resubmit data if necessaryAdditional data may be requested to support
Data “locked” after 4-6 weeks for analysis and reportingSubmissions after this point may be excluded
Potential Compliance Actions
Compliance considered timely submission of accurate data
Warning notices, and/or request corrective action plans– Based on significance and/or persistence of non-
compliance
Intermediate sanctions (suspending marketing/enrollment activities), civil monetary penalties (CMPs), or contract termination if persistent non-compliance
For More Part D Information
CY2008 Reporting Requirements and related guidance:
www.cms.hhs.gov/PrescriptionDrugCovContra/01_Overview.asp
Questions [email protected]
