Annual Verification of Parent Organization and Legal Entity Name for Medicare Plans Due by March 19, 2025
Relevant to: PDP, 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.
Review the full CMS Memo here.
Introduction
February 2025 marks an important period for Medicare Advantage, Prescription Drug Plan, Cost, PACE, and Medicare-Medicaid Plan organizations. The Centers for Medicare & Medicaid Services (CMS) have announced the annual verification process for the parent organization and legal entity names listed in the Health Plan Management System (HPMS). Organizations must review and report any changes or corrections by March 19, 2025, ensuring compliance and accurate representation in official documents.
Key Dates and Deadlines
- Deadline to report necessary corrections of parent organization and legal entity name: March 19, 2025
- Notify CMS of changes within 30 days from the effective date if changes occur after March 19, 2025
PACE Compliance
This memo is relevant to PACE programs because it mandates the annual verification of the parent organization and legal entity name for all contracting organizations, including PACE. This ensures that the information listed in the Health Plan Management System (HPMS) is accurate and up to date. Compliance requires that PACE organizations review their listings and report any necessary changes or corrections to CMS by the specified deadline of March 19, 2025.
PACE organizations must ensure that their legal entity names and parent organization statuses are correctly reported according to official documents like articles of incorporation or licenses. Any discrepancies must be reported immediately via email to PartD_Monitoring@cms.hhs.gov. Further, changes that occur after the deadline must be reported within 30 days of their effective date.
Information pertaining to parent organizations and legal entities is accessible in the HPMS through the Basic Contract Management Module, under the navigation pathway specified in the memo. PACE organizations cannot directly alter this information themselves and must communicate changes to CMS, including detailed documentation supporting such changes.
When submitting changes, it is important to include the contract number and specify whether it is a ‘parent organization update’ or ‘legal entity update’ in the email subject line. Organizations should provide details on what prompted the change and include contact information for further discussion if needed. Supporting documentation, such as financial statements or articles of incorporation, must display the official state seal or Secretary of State’s signature. Minor changes not agreed upon by CMS, such as abbreviation expansions, may not be updated due to system character limitations.
This diligent reporting and documentation process is crucial for maintaining the integrity and accuracy of the CMS’s records concerning PACE and other contracting organizations.
Required Actions
1. Conduct an annual review of your organization’s parent organization and legal entity name as listed in the Health Plan Management System (HPMS).
2. Report any corrections to CMS by sending an email to PartD_Monitoring@cms.hhs.gov by March 19, 2025, including your contract number(s) and documentation to support any changes.
3. If any changes occur after March 19, 2025, notify CMS within 30 days of the effective date by emailing the required information and documentation.
FAQs
- “What is the purpose of the annual verification of parent organization and legal entity name?”
- “How can contracting organizations access their parent organization and legal entity name information?”
- “What should be done if there is an error in the parent organization or legal entity name information?”
- “What type of documentation is required for making changes to the parent organization or legal entity name?”
- “Who should be contacted for questions regarding the verification process?”
