Proposed Change to CMS CY2024 Part C Reporting Requirements – NEW Category Added

CMS Regulatory Change:

CMS is proposing an additional Part C reporting requirement for supplement benefits. This is scheduled to be an annual reporting requirement, due the last Monday in February of the following calendar year.

Published in the Federal Register Vol. 88, No. 184 on September 25, 2023 and also on the CMS web site, PRA listing CMS-10261. Comments on the collection of information must be received by the OMB desk officer by October 25, 2023. Written comments and recommendations for the proposed data collection should be sent here.

This request stems from recommendations from members of the United States Congress, the Medicare Payment Advisory Commission (MedPAC), Government Accountability Office (GAO), and other industry stakeholders. In addition, this information also addresses the new MLR reporting requirements (87 FR 27704) on supplemental benefits, as well as the limited information submitted in the Plan Benefit Package (PBP) categories and subcategories.

The proposed new reporting requirement will be section VIII. SUPPLEMENTAL BENEFIT UTILIZATION AND COSTS.

Some data elements are straightforward: element A. PBP Category, B. supplement benefit name, C. how the benefit is offered, and E. the number of enrollees eligible. However, the unit of utilization needs to be defined, element D, and captured to be able to report and track element F. the number of enrollees who utilized the benefit at least once, G. the total instances of utilization among eligible enrollee and H. the median number of utilizations among enrollees utilizing the benefit at least one. The total net amount incurred by the plan to offer the benefit, element I, is a financial measure and needs to track to your contracts/agreements with vendors, along with element J, the type of payment arrangement. This is further delineated in element K. how the plan accounts for the cost of the benefit, including administrative costs, cost to deliver and any other costs. Finally, element L reports the total out-of-pocket cost per utilization for enrollees who used the benefit.

CMS states that this reporting will provide key data to CMS on the utilization and cost of these benefits. Somewhat similar Part C Reporting Requirements on benefit utilization were required from 2008-2011. This proposed collection builds upon the previous collection by separating by PBP category and requests data to be split out by the type of supplemental benefit (mandatory, optional, mandatory-SSBCI, mandatory-Uniformity Flexibility).

The full summary of data elements and types of supplemental benefits specified in the reporting requirements can be found at Form Number CMS-10261.

Be sure to submit your comments by October 25, 2023.

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