Section 1852(e) of the Social Security Act requires that MA organizations (MAOs) have an ongoing quality improvement program. CMS regulations at 42 CFR §422.152 outline the quality improvement program (QI Program) requirements for MA plans, which includes the development and implementation of both a Quality Improvement Project (QIP) and a Chronic Care Improvement Program (CCIP). The 2014 approved packaged reflected a process that required plans to report QIP and CCIP projects’ progress reports annually. This reinstatement package outlines the burden for the attestation process that reduces burden by requiring plans to attest annually that they have an ongoing CCIP that meets the requirements outlined at 42 CFR §422.152, rather than report annual progress reports. MA plans will only have to attest to having a CCIP once the proposed rule (CMS-4182-F; RIN 0938-AT08) that removes the QIP is final.
In this information collection request, MAOs would no longer be required to submit CCIP and QIP progress reports to CMS annually. In its place, we have transitioned to an annual attestation requirement. MAOs are now required to annually attest that they have ongoing CCIPs and QIPs electronically via the Health Plan Management System (HPMS). The attestation involves no reporting of information or data. Consequently, the attestation requirements and burden are not subject to OMB approval under the PRA.
Unlike the non-rule related attestation which is exempt from the PRA, the final rule (CMS-4182-F, RIN 0938-AT08) attestation will require that MA organizations identify what conditions their CCIP projects are focusing on thereby making it subject to the requirements under the PRA.
On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control number;
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.