2025 Medicare Part D Reporting Updates: New Requirements & Technical Specs

Relevant to: PDP, 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.

Disclaimer: The content provided on this site is a summary for informational purposes only, and Grane PBM, Inc. assumes no liability for any errors or omissions in the site’s content. The information does not constitute legal or regulatory advice or replace the original CMS memo. Readers are advised to consult the CMS memo in its entirety and to verify information independently before making any decisions based on this information.

Click here to read the complete memo from CMS.

Introduction

CMS has published the updated Contract Year 2025 Part D Reporting Requirements, introducing a change that removes the Reopenings Plan ID from certain reporting sections. Additionally, the finalized Technical Specifications have been issued, following feedback on the draft. These documents are accessible on the CMS website and will be on the HPMS Plan Reporting site by January 2025.

Key Dates and Deadlines

  • Release Date for Updated CY 2025 Part D Reporting Requirements: December 5, 2024
  • Availability on HPMS Plan Reporting site: January 2025

PACE Compliance

The CMS memo regarding the updated CY 2025 Part D Reporting Requirements is relevant to PACE (Programs of All-Inclusive Care for the Elderly) programs primarily due to its implications on reporting and compliance. These updates in reporting requirements ensure all Medicare-related services, including those involving prescription drugs, align with federal standards and regulations.

Although there are no direct changes to PACE-specific regulations mentioned in this memo, it is important for PACE organizations to be aware of changes in Part D reporting that could indirectly affect their operations or reporting practices. Compliance with Part D reporting requirements is fundamental to ensure transparency and accuracy in the delivery of drug-related services within PACE programs.

PACE organizations should:

1. Review the updated CY 2025 Part D Reporting Requirements in detail to understand any potential implications for their programs.
2. Ensure that internal reporting mechanisms are capable of aligning with the new requirements to maintain compliance.
3. Consider the removal of the Reopenings Plan ID element and understand how this non-substantive change might impact their record-keeping and reporting activities, especially in relation to contract-level submissions.
4. Stay informed about the final Technical Specifications and any other potential updates released later that could further influence their compliance processes.

Staying up-to-date with these requirements will help PACE organizations avoid non-compliance and potential disruptions in service delivery and funding. Careful monitoring and adaptation to these regulatory changes are essential for maintaining the integrity of PACE operations and services.

Required Actions

The Centers for Medicare & Medicaid Services (CMS) released updated CY 2025 Part D Reporting Requirements. We made a non-substantive change to remove the Reopenings Plan ID element in the Coverage Determinations, Redeterminations (including–Risk Redeterminations under a Drug Management Program), and Reopening reporting section since this section is collected at the Contract level. We also released the Technical Specifications after considering comments on the draft Technical Specifications for the Medicare Prescription Payment Plan reporting section. Both documents have been posted on the CMS website at the following link and will also be available on the HPMS Plan Reporting site in January 2025: www.cms.gov/medicare/coverage/prescription-drug-coverage-contracting/part-d-reportingrequirements. Questions regarding the CY 2025 Part D Reporting Requirements and Technical Specifications should be emailed to partd-planreporting@cms.hhs.gov. Emails should include the title of the specific data element to which your question applies in the subject line.

FAQs

  • “What are the CY 2025 Part D Reporting Requirements?”
  • “What changes were made to the Part D Reporting Requirements for 2025?”
  • “Where can I find the Technical Specifications for the 2025 reporting year?”
  • “How do I ask questions regarding CY 2025 Part D Reporting Requirements and Technical Specifications?”

Click here to read the complete memo from CMS.

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