Dear Sir or Madam:
On behalf of the Regulatory Relief Coalition, including the undersigned professional associations, we are
pleased to have the opportunity to comment on the Paperwork Reduction Act notice published in the
Federal Register on March 26, 2018. See 83 Federal Register No. 58 (March 26, 2018) (the “MAO
Reporting Requirement Notice” or the “Notice”). This Notice solicits comments on the information that
Medicare Advantage Organizations (MAOs) will be required to report to CMS in 2019 in the form
entitled, “Part C Medicare Advantage Reporting Requirements.”
As indicated in the Notice, MAOs are required to have an effective procedure to report to CMS statistics
and other information with respect to (among other things) patterns of service utilization and the
availability, accessibility and acceptability of its services. In the Notice, CMS proposes to add 18 new
data elements to the reporting requirements applicable to Organization Determinations and
Reconsiderations (ODR). We support the inclusion of the proposed new data elements to provide CMS
with additional information regarding the circumstances under which ODRs are made. In addition, we
believe that it is critical to add a number of additional new data fields to collect information relating to
MAOs’ use of Organization Determinations that are made pursuant to Prior Authorization (PA) processes
and procedures.
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