2025 Medicare Part D COB-OHI Full Replacement File Update
Relevant to: PDP, COB, PACE, Part D
Each week, we scan the latest CMS memos to find the most important ones that apply for PACE programs. Below is a summary of what you need to know.
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To read the full memo from CMS, click here.
Introduction
The Centers for Medicare & Medicaid Services has announced the distribution of the 2025 Annual Coordination of Benefits-Other Health Insurance Full Replacement File. Targeted at all Part D sponsors, this directive is crucial for managing comprehensive beneficiary records related to prescription drug coverage. It encompasses active participants in the Part D program over the past three years, ensuring that organizations maintain accurate and up-to-date information on other health insurance coverage.
Key Dates and Deadlines
- Memo Date: February 13, 2025
- Annual COB-OHI File Transmission Start Date: March 17, 2025
- Daily COB-OHI Files Resumption: Approximately 1 week after March 17, 2025
PACE Compliance
This memo is relevant to PACE programs because it outlines the process for the annual Coordination of Benefits-Other Health Insurance (COB-OHI) full replacement file, which is crucial for maintaining accurate Part D beneficiary records within PACE organizations.
PACE organizations, like other Part D sponsors, must ensure that they handle the annual COB-OHI files appropriately by:
– Investigating unexpected or missing OHI records in their systems. This includes verifying that beneficiaries with Other Health Insurance (OHI) coverage are accurately represented.
– Updating beneficiary profiles when discrepancies are identified, particularly for cases where OHI records are not received or when records received have already been deleted from the Coordination of Benefits & Recovery Center (BCRC) system.
Failure to comply with these processes can result in inaccurate reporting and potential compliance issues. The annual COB-OHI file transmission is scheduled to begin on March 17, 2025. PACE organizations must ensure their systems are equipped to receive and process these files correctly.
Pace organizations should note that while the daily COB-OHI files are on hold during the annual file processing, any updates will resume approximately one week after the full replacement file transmission is complete. An email notification will be provided by CMS indicating the number of files transmitted and the resumption date for daily COB-OHI files.
Required Actions
1. Check for upcoming receipt of the annual COB-OHI full replacement file starting March 17, 2025. Part D sponsors should validate all files received, using the provided summary file for confirmation.
2. Investigate and update beneficiary OHI profiles for unexpected or missing OHI records. This includes scenarios where there may be discrepancies between internal systems and the annual replacement file.
3. Refer to the Plan Communication User Guide, specifically section 3.7 “Coordination of Benefits,” and Chapter 14 of the Medicare Prescription Drug Benefit Manual for guidance on using COB-OHI data for related activities.
FAQs
- “What is the Annual Coordination of Benefits-Other Health Insurance (COB-OHI) full replacement file for 2025?”
- “How do Part D sponsors investigate unexpected or missing OHI records?”
- “What is the transmission timeline for the annual COB-OHI full replacement file?”
- “Why might Part D sponsors receive multiple COB-OHI files over several days?”
- “What resources are available for understanding COB-OHI data?”
