2025 PDE Submission Certification for PACE Organizations: Requirements & Changes
Relevant to: PDF, 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.
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 memorandum from CMS.
Introduction
CMS has released an important memo for PACE Organizations regarding the 2025 Prescription Drug Event Submission Certification Requirements. This initiative demands recertification from all Part D sponsors, including PACE organizations, due to changes in PDE filing, such as new financial fields and layout expansion. Certification testing, beginning September 1, 2024, will allow organizations to adjust to new protocols before the January 1, 2025 deadline.
Key Dates and Deadlines
- Certification testing for non-PACE Part D sponsors began on July 1, 2024.
- The memorandum for PACE Organizations was released on July 12, 2024.
- Certification testing for PACE organizations will begin on September 1, 2024.
- PDE submissions in production must be certified beginning on January 1, 2025.
- The HPMS memo with additional information was issued on June 28, 2024.
PACE Compliance
This memo is relevant to PACE programs because it outlines the certification requirements for submitting Prescription Drug Event (PDE) data, which are crucial for PACE organizations due to upcoming changes in the PDE File Layout.
PACE organizations are required to recertify in order to submit PDE data starting January 1, 2025. This recertification is mandatory because of changes such as the PDE File Layout expansion and new financial fields introduced for the Manufacturer Discount Program.
Certification testing for PACE organizations begins on September 1, 2024. It is important that PACE organizations do not submit testing and certification files before this date. Additionally, certification must be achieved before submitting PDEs in production starting January 1, 2025.
PACE organizations will be participating in two phases of certification testing, distinct from non-PACE Part D sponsors, which began their testing on July 1, 2024.
PACE organizations might encounter modified or new PDE edits in the testing and certification environment. They should refer to the current PDE Edit Spreadsheet to interpret these edits and must incorporate the changes discussed in the HPMS memorandum from June 28, 2024.
Some edits, such as 655 and 656, do not apply to PACE organizations since they do not submit those values on the PDE record. However, edits like 803 on invalid LICS amounts for specific Dates of Service (DOS) and 821 indicating invalid NPP amounts are critical for ensuring compliance.
The successful completion of certification testing is required for PACE organizations to continue their operations without interruptions. This will lead to formal notification by CSSC Operations and updates in the Prescription Drug Front-end System (PDFS) to allow production file transmissions.
Required Actions
As described in previously published HPMS memoranda, CMS will require all Part D sponsors, including PACE organizations, to recertify in order to submit Prescription Drug Event (PDE) data beginning January 1, 2025. This program-wide recertification is necessary due to upcoming PDE changes, including the PDE File Layout expansion and the introduction of new financial fields on the PDE record in support of the Manufacturer Discount Program (Discount Program).
Certification testing will occur in two phases. Certification testing for PACE organizations will begin on September 1, 2024, as outlined in this memorandum. PACE organizations should follow the testing and certification protocol indicated at www.csscoperations.com
1. Begin certification testing on September 1, 2024, by following the 2025 PDE Testing and Certification Protocol for PACE organizations as posted on the CSSC Operations website.
2. Do not submit certification files prior to September 1, 2024. Ensure to achieve certification status before submitting PDEs in production by January 1, 2025.
3. Review and prepare for the new and modified PDE Edits applicable starting January 1, 2025, as outlined in the HPMS memo, especially focusing on exceptions or additions specific to PACE organizations.
FAQs
- “What are the new PDE (Prescription Drug Event) submission certification requirements for 2025?”
- “When will the certification testing for PACE organizations begin and what is the deadline?”
- “How will the 1000-byte Transaction Validation Detail Report affect PDE submissions?”
- “Which specific edits do not apply to PACE organizations according to the 2025 certification memo?”
- “Where can I find additional resources and updates related to the 2025 Prescription Drug Event submissions?”
