CY 2022 Part C and Part D Reporting Technical Specifications – Do You Know What Has Changed?

In June, CMS issued updated technical specifications for CY 2022 Medicare Part C and Part D reporting. BluePeak has summarized the key changes in the technical specifications below.

BluePeak compared the 2021 requirements to the updated 2022 requirements and identified updates in the following areas:

2022 Part D Technical Specifications

• The 2022 reporting exclusions were updated or clarified as follows:
  • If a contract terminates before July 1^st in the following year after the contract year (CY) reporting period, the contract is not required to report any data for the respective two years – the CY reporting period, and the following year.
    • Example: Contract terminates June 2022. Contract will not report CY 2021 (“CY reporting period”) or CY 2022 data (“following year”).
  • If a Plan Benefit Package (PBP) under a contract terminates at any time in the CY reporting period and the contract remains active through July 1^st of the following year, the contract must still report data for all PBPs, including the terminated PBP.
• CMS also added clarification for the Medication Therapy Management (MTM) reporting section which states that if a beneficiary meets both sets of targeting criteria for the MTM program (multiple chronic diseases/multiple Part D drugs/cost threshold AND drug management program at-risk beneficiary) as specified in 42 CFR 423.153(d)(2), sponsors should report the date the beneficiary first met either set of the targeting criteria.
• For CY 2022, Improving Drug Utilization Review Controls (DUR) must be reported at the Contract level. Previously this was reported at the Plan/PBP level. In addition, CMS clarified that for elements F, S, X and BB of the safety edits, as defined in the 2022 Part D Reporting Requirements, a beneficiary who is a resident of a long-term care facility, is receiving hospice, palliative or end-of-life care, has sickle cell disease, or is being treated for active cancer related pain is exempt from these safety edits. This excludes beneficiaries who are not opioid naïve, who are reported in elements Y and CC.
• The Coverage Determinations and Redeterminations (CDR) Section added the following:
  • For coverage determinations and redeterminations, if the plan processes a timely withdrawal request, the plan must report both the withdrawn coverage determination request and the plan’s dismissal of that coverage determination request.
  • At-risk determination appeals (beneficiary-specific point-of-sale (POS) edit, or prescriber or pharmacy coverage limitation appeals, sharing information for subsequent Part D enrollments) made under a drug management program should be counted as a redetermination.

2022 Part D Reporting Requirements

• The Reporting Requirements for Part D also had several changes. There were new data elements added to the reporting for MTM, DUR and CDR, as well as the removal of previous data elements from these reports and the Enrollment/Disenrollment report.

2022 Part C Technical Specifications

• While there were fewer changes in Part C than in Part D, CMS added the following exclusions in the Part C Organization Determinations/Redeterminations Section of the Part C Reporting Technical Specifications:
  • An appeal by an enrollee (or other party) of the plan’s dismissal of a coverage determination
  • A decision by the plan to uphold or reverse its dismissal of an organization determination as a result of an enrollee (or other party) appealing a dismissal
  • Plan decisions regarding a request to vacate a dismissal.

What Do Plans Need To Do Next?

Plan sponsors should carefully review these requirements from CMS and identify any changes. Business owners should identify changes applicable to their areas and meet with the reporting teams to provide new requirements. It is important to do this early so there is sufficient time for system updates and new reports to be thoroughly tested and the changes validated, prior to the reporting deadlines starting in February 2023. If you have not started this process, BluePeak recommends doing this now to avoid the risk of inaccurate or untimely reporting.