Skip to Main Content

You are using an outdated browser. Please upgrade your browser to improve your experience.

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

2025 Data Validation (DV) Activities

DV Phase 1: Planning for DV Activities
StepResponsible PartyDV ActivitiesTimeline*
1Sponsoring Organization (SO)Select independent DVC based on Standards for Selecting a Data Validation Contractor (Appendix A).December - March
2Data Validation Contractor (DVC), SONotify CMS of DVC Selection/Request Access to Health Plan Management System (HPMS) Plan Reporting Data Validation Module (PRDVM).

Enter/Update the DVC organization in HPMS. If applicable, enter/update the pre-assessment consultant in HPMS.
January - April
3DVC, SOComplete the web-based Data Validation training.February - March
4DVC, SOReview all DV documents.January - March
DV Phase 2: Performing DV Activities
StepResponsible PartyDV ActivitiesTimeline*
5SOComplete Organizational Assessment Instrument (OAI), also known as Appendix E, and provide appropriate documentation to selected DVC per the OAI’s documentation requestMarch - April
6DVC, SOAnalyze OAI (Appendix E) ResponsesMarch or later
7DVC, SOPrepare for on-site or virtual visit (site visit agenda, resource needs, and logistics)Early April
8DVC, SOConduct on-site or virtual review (convene entrance conference, conduct interviews with SO staff, observe SO’s reporting processes, and get census and/or sample files)Early April
9DVCRequest additional documents following on-site or virtual visit (if applicable)Mid/Late April
DV Phase 3: Analyzing Results & Submission of Findings
StepResponsible PartyDV ActivitiesTimeline*
10DVCDetermine compliance with Data Validation Standards by recording findings in the EES (Appendix B)April - June 15
11DVCSubmit EES findings to CMS via HPMS PRDVM and get DV scoresNo later than June 15
DV Phase 4: Completing Post-Activities
StepResponsible PartyDV ActivitiesTimeline*
12DVC, SOCompile archive of DV work papersNo later than June 15
13DVCProvide draft findings to the SONo later than June 15
14DVC, SOReview EES findings and make necessary technical and factual correctionsNo later than June 15
15SOAppeal DV determinations (if applicable)5 business days following the DV deadline

*References to December refer to the calendar year before the DV review; all other references to months refer to the same calendar year as the DV review.

Reporting Sections Eligible for Validation in the 2025 DV Cycle

DVCs evaluate the following Part C reporting sections:
Name of Part C Reporting SectionReporting YearReported by SO to CMS Annually, Bi-Annually, or QuarterlyFile Upload Into HPMS Yes/No
Grievances2024AnnuallyYes
Organization Determinations/ Reconsiderations2024AnnuallyYes
Special Needs Plans (SNPs) Care Management2024AnnuallyYes
DVCs evaluate the following Part D reporting sections:
Name of Part D Reporting SectionReporting YearReported by SO to CMS Annually, Bi-Annually, or QuarterlyFile Upload Into HPMS Yes/No
Medication Therapy Management (MTM) Programs2024AnnuallyYes
Grievances2024AnnuallyYes
Coverage Determinations, Redeterminations, and Reopenings2024AnnuallyYes
Improving Drug Utilization Review (DUR) Controls2024AnnuallyYes