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2025 Medicare Part C & Part D Reporting Requirements & Data Validation

Guidance for DV Standard 3

Implementation Guidance

(Sub-Standards 3.a & 3.b)

Determine who’s responsible for entering and uploading data into CMS systems for each reporting section under review and if the SO wrote work instructions or policies and procedures for the entry or submission of the Part C and Part D Reporting Requirements.

Evaluate Sub-Standards 3.a and 3.b by performing the following actions:

  • Assess the Submission Activity Report from the HPMS PRDVM by performing the following:
    • Ask for a copy of the contract’s Submission Activity Report from the SO: This report displays information about the original submission and all subsequent resubmissions for particular contracts. The report also displays Reporting Period, Contract Number, Plan ID, Submission Version, Due Date and Date Submitted for each section.

For either of the above scenarios, the DVC should clearly document the circumstances in the “Data Sources and Review Results” section of the EES (Appendix B).

Assess the census/or sample data provided by the SO to determine each of the following for each reporting section under review:

  • SOs selected data records properly:
    • Perform frequency calculations to list all unique occurrences of data fields pertinent to the calculation of the data element to verify they contain values within an acceptable range for the data field.
    • Calculating frequency of occurrence for certain data fields might also alert the DVC to obvious mistakes in the data extraction.
  • SOs merged or joined individual data sets correctly to create final stage data sets:
    • Sample a few records, when individual data sets are available, often intermediate ones, from the individual data sets to confirm that they were joined properly.
    • Check for duplicate records and determine if record counts for the component data sets agree with those found in the merged data set.
  • SOs calculated all data elements correctly:
    • Recalculate the data fields that the SO used to calculate the data elements and refer to CMS guidance documents and technical specifications.
    • Calculate sums of individual records within each reporting section to make sure that they equal those reported to CMS.
    • Compare the data file created for submission to CMS with the data entered in the HPMS to confirm no manual data entry errors. For file uploads, confirm that the data file adheres to the record layout specified in HPMS.

For the reporting sections that need reporting at the PBP level, if the DVC finds that the SO didn’t correctly enter or upload data reported for any of the PBPs included under a contract, then the reviewer should assign a “No” finding in the EES (Appendix B) for the entire contract for the applicable data elements for Sub-Standards 3.a and 3.b.

If a reporting section requires both a file upload and data entry, both occur for an SO to meet Sub-Standards 3.a and 3.b.

DVCs confirm that the data doesn’t have any logical errors. The DVC should perform data integrity checks to verify at the data element level. These data integrity checks include confirming that a data element doesn’t include outlier records.