December 9, 2019 - FM Payment Processing 2019 Q4

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December 9, 2019 - FM Payment Processing 2019 Q4
FM Payment Processing 2019 Q4
Policy-based Payments (PBP): Upper Bound
Adjustments, 1095-A Reminder, and Payment
         Dispute Guidance Updates

                 December 9, 2019
           Division of Financial Transfers and Operations
                                                  (DFTO)
   This communication was printed, published, or produced and disseminated at U.S. taxpayer expense. The information provided in this presentation is
   only intended to be a general informal summary of technical legal standards. It is not intended to take the place of the regu lations that it is based on.
   We encourage audience members to refer to the applicable regulations for complete and current information about the requireme nts that apply to
   them.
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December 9, 2019 - FM Payment Processing 2019 Q4
Session Guidelines

 • This is a 60-minute webinar session
 • For questions regarding content, submit
   inquiries to fmcc@cms.hhs.gov
 • For questions regarding logistics and
   registration, contact the Registrar at:
   (800) 257-9520

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December 9, 2019 - FM Payment Processing 2019 Q4
Agenda

 • Policy-based Payments (PBP): Upper Bound
   Adjustments
 • 1095-A Reminder
 • Payment Dispute Guidance

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December 9, 2019 - FM Payment Processing 2019 Q4
Policy-based Payments (PBP):
 Upper Bound Adjustments

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December 9, 2019 - FM Payment Processing 2019 Q4
Temporary Manual Adjustments for FFE and
SBE-FP Issuer

 January and February 2020 Policy-based Payments (PBP):
 •   Historically, advance payments in the January and February monthly payment cycles experience a lag
     caused by premium collection and reporting of policy effectuations beyond the December 15th cutoff
     for payment reporting.
 •   Centers for Medicare & Medicaid Services (CMS) will make a temporary manual adjustment (Upper
     Bound) to the January and February 2020 PBP for Federally-facilitated Exchange (FFE) Issuers and
     Issuers in State-based Exchanges using the Federal platform (SBE-FP) offering major medical plans.
 •   This adjustment is intended to mitigate the cash flow impact of the transition to 2020 for FFE and
     SBE-FP Issuers on PBP.
 •   The Upper Bound adjustments will be applicable to only APTC and UF payments and charges and will not
     apply to CSR which has been discontinued as of October 2017 payment cycle.
 •   Adjustment(s) will show on the Issuers’ Preliminary Payment Report (PPR) and HIX-820s as two
     separate manual adjustments to APTC and User Fees.
 •   Note: CMS will also be making payment adjustments to some State-based Exchange (SBE)
     issuers that have transitioned to policy-based payments as established through CMS discussions
     with each SBE. CMS will notify issuers in each state of planned adjustments for their state.

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December 9, 2019 - FM Payment Processing 2019 Q4
Temporary Manual Adjustments for FFE and
SBE-FP Issuers (continued)

January and February 2020 PBP Upper Bound Adjustment:
•   CMS will calculate this adjustment using a payment estimate equal to 80 percent of the estimated
    PBP on effectuated enrollment plus enrollment still in “initial” status (i.e., “Upper Bound”).
•   If the Issuer’s calculated YTD PBP are less than 80 percent of this amount, CMS will apply an
    adjustment to increase the Issuer’s advance payment, net of FFM user fees, up to the 80 percent
    threshold.
•   CMS will not make any downward payment adjustments to Issuers whose total calculated Policy-
    based Payments equal or are above the 80 percent threshold.
•   Note: It is currently planned that calendar year 2020 will be the last year that CMS will issue Upper
    Bound adjustments and therefore the adjustments will not be issued in January and February 2021
    or any year thereafter.

                 CMS defines the Payment Upper Bound as the payment that would be
                 due for all non-cancelled enrollment (regardless of effectuation status)

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December 9, 2019 - FM Payment Processing 2019 Q4
Temporary Manual Adjustments for FFE and
SBE-FP Issuer Transition (continued)

 Reversing Upper Bound Manual Adjustments:
 February 2020:
   •   If there was an Upper Bound Adjustment for January 2020, CMS will
       reverse this temporary manual adjustments in February 2020 payment
       cycle and recalculate the Upper Bound to see if the year-to-date total
       Policy-based Payment reached the 80 percent threshold.
         • If the 80 percent threshold is reached, no other temporary
            adjustments will be made and Issuer will be paid on system
            calculated PBP amounts only from this point forward.
         • If the 80 percent threshold is not reached, one last temporary
            Upper Bound adjustment will be made for February 2020 payment
            cycle which will be reversed in March 2020 payment cycle.

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Temporary Manual Adjustments for FFE and
SBE-FP Issuer Transition (continued)

  Reversing Upper Bound Manual Adjustments
  March 2020:
    •   If there was an Upper Bound Adjustment for February 2020
        Payment cycle, CMS will reverse this temporary Upper Bound
        manual adjustments in March 2020 Payment cycle. This would
        be the last Upper Bound reversal. All future payments will be
        made on system calculated PBP amounts only.
    •   All Issuers from this point will be paid based on system
        calculated PBP amounts.
    •   Adjustment(s) will show on the Issuers’ Preliminary Payment
        Report (PPR) and HIX-820s as two separate manual
        adjustments to APTC and User Fees.

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Upper Bound Payment Cycle: 80% Cap

            Examples: Year to Date APTC Payments:
                              80% of
                      Upper
             PBP              Capped                                             Total
                      bound          PBP APTC Amount < 80       Temporary
            APTC               APTC                                              APTC
  Scenario            APTC           % of Capped APTC Upper Adjustment applied
           Amount              Upper                                            Amount
                     Amount               Bound Amount?        to Payment
            (YTD)             Bound                                            Paid YTD
                      (YTD)
                              Amount

     1     $90.00   $110.00   $88.00            No                 $0.00       $90.00

     2     $70.00   $110.00   $88.00            Yes               $18.00       $88.00

     3     $40.00   $100.00   $80.00            Yes               $40.00       $80.00

     4     $65.00    $80.00   $64.00            No                 $0.00       $65.00

                    Note: The same calculation will apply to User Fees

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Upper Bound Example

             Upper Bound
               Example

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Exchange Payment Type Codes for FFE/SBE-FP
Policy-based Payments

 Year                                                         Exchange        Coverage Period Coverage Period
        Issuer Type        Process      Transaction Type
                                                              Payment Type    Start Date      End Date
                                        Retroactive
        FFE and SBE-FP                                        APTCADJ, CSRADJ,
 2019                      PBP          Adjustments – APTC,                    2019MMDD       2019MMDD
        Issuers                                               UFADJ
                                        CSR, UF

                                                           UFRMADJ,
        FFE/SBE-FP UFR     MA, Manual                      APTCMADJ,
 2019                                   APTC, CSR, UF, UFR                    2019MMDD        2019MMDD
        adjustments        workbooks                       CSRMADJ,
                                                           UFMADJ

                                        Prospective and       APTC, CSR, UF
        FFE and SBE-FP                  Retroactive
 2020                      PBP                                                2020MMDD        2020MMDD
        Issuers                         Adjustments – APTC,   APTCADJ,
                                        CSR, UF               CSRADJ, UFADJ

                                                           UFRMADJ,
        FFE/SBE-FP UFR and
                           MA, Manual                      APTCMADJ,
 2020   January temporary               APTC, CSR, UF, UFR                    2020MMDD        2020MMDD
                           workbooks                       CSRMADJ,
        Manual adjustments
                                                           UFMADJ

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References

• 2019 Manual Adjustments Guidance:
  https://www.regtap.info/reg_librarye.php?i=2731
• Enrollment, Payment Processing, and Invoicing New Issuer Training
  (FFEs): https://www.regtap.info/reg_librarye.php?i=3084
• Early Year Payment Adjustment Issuer Slides:
  https://zone.cms.gov/document/november-9th-2018-issuer-meeting-
  slides
• Financial Management Overview for 2020 SBE Issuers:
  https://www.regtap.info/reg_librarye.php?i=3083

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1095- A Reminder

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1095-A Reminder

•   This is a friendly reminder to make sure your 2019 enrollment information is accurate and up-to-
    date for the upcoming release of 1095-As to your members
     – Check all remaining “initial” enrollments on your RCNI file
           • Submit effectuation or cancellations to CMS through enrollment reconciliation or the
               dispute process.
           • Check all remaining “I” and “F” flags on your RCNO file
           • Make updates to your enrollment system or submit disputes or reconcile with CMS to
               make corrections as necessary
     – Submit timely grace period expiration terminations to CMS through inbound 834s or
         enrollment recon
     – Submit disputes to CMS to correct any remaining enrollment reconciliation issues by
         12/23/19
     – Submit Enrollment Reconciliation updates in the December RCNI

            Errors in 2019 enrollment that remain in January will lead to 1095-A errors,
            consumer disputes, research costs for CMS and issuers, and a poor customer
                                   experience for your members

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Payment Dispute Guidance

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Payment Dispute Guidance

     I.   Payment Dispute Reminders
     II.  Enrollment Dispute Form v12 Deployment
     III. New Detail Codes:
         1.   PD942
     IV. Modified Detail Codes:
         1.   PD533
         2.   PD645 & PY645
     V.   Reminder: AM Approval of Prior Year Disputes
     VI. Common Errors: Avoiding FV9
     VII. zONE Publications

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Payment Dispute Reminders

•   Please submit your Payment Disputes!
    – Submit a Payment Dispute for any record perceived to be incorrect.
    – Issuers may submit large volumes of Payment Disputes without impeding
      processing time.

•   Payment Dispute Support
    – As a reminder, the FMCC team is the primary point of contact for resolving
      rejected Payment Disputes. Please reach out to the FMCC team at
      FMCC@cms.hhs.gov with any questions regarding rejected Payment
      Disputes.

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Reminder: AM Approval for Prior Year
Disputes

 •   Issuers must get approval from their Account Manager (AM) before
     submitting prior year disputes.
 •   AM approval is not required for HICS Direct Disputes or prior year disputes that
     contain supporting HICS cases.
 •   Issuers must email a completed Issuer Prior Year Approval Request Form to
     their AM to request prior year dispute approval. The form is available on zONE:
      – https://zone.cms.gov/system/files/documents/issuerprioryearapprovalrequest.xlsx
 •   Upon receiving a confirmation email from ER&R, issuers should submit the
     approved prior year disputes before the due date.
 •   ER&R will return prior year disputes submitted after the AM-approved deadline
     with detail code FV110.
 •   ER&R will return prior year disputes that did not receive AM approval and do not
     contain a supporting HICS case with detail code FV111.

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Enrollment Dispute Form v12 Deployment

 •   ER&R began accepting Enrollment Dispute Form v12 on Tuesday,
     November 12th.
 •   CMS published the final v12 production file (enrollmentdisputeformv12.xlsx) to
     zONE.
      – https://zone.cms.gov/document/enrollment-resolution-and-reconciliation
 •   ER&R will return any Enrollment Disputes submitted using v11 with instructions
     to resubmit using v12.
 •   Issuers who wish to use add-ins when submitting disputes must download and
     install the new Enrollment Dispute v12 Add-ins from zONE.
      – The instructions for installing and using the add-ins are on the PSV Format tab of the
        Enrollment Dispute Form; however, issuers should contact their IT department before
        installing the add-ins.
      – Prior to installing the new version, issuers should uninstall any previous version.

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Detail Code for Disputes Where an FFM
Payment Was Made

 •   New Detail Code: PD942
 •   PD942 applies to a dispute for a missing payment that initially received an In
     Process disposition code and subsequent manual analysis found a payment was
     made by the FFM.
     NOTE: PD942 is similar to PD511, which also indicates that a payment was
     found in the PPR for the “missing payment” disputed policy. The two are different
     in that PD511 is resolved through automated business rules, whereas PD942
     required additional analysis, likely because multiple payments were made on
     multiple segments within the policy.
      – PD942 Issuer Action: Review the PPR or HIX 820 reports for payments on
          the disputed policy. If the payments are incorrect, submit a dispute with the
          FFM values and appropriate HICS Case ID for APTC or Total Premium
          disputes.
 •   PD942 results in disposition code C6: Timing Issue – PPR Record Found.

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Modified Detail Code for Policies to Be
Cancelled by the FFM

•   PD533 applies to disputes where the issuer is reporting an unexpected
    payment on a policy that will be cancelled by the FFM in the upcoming
    cycle.
•   PD533 modifications are as follows:
     – Previously, PD533 only applied to disputes involving uneven or unexpected
       RCNO records with record-level flags of F, G, W, or L.
     – Going forward, PD533 will also be used for disputes involving uneven RCNO
       records with record-level flags of V as well as instances where the issuer
       reported an Issuer Premium Paid Indicator of C for the disputed record.
•   PD533 results in disposition code I1: In Process.

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Modified Detail Codes for Unexpected
Payments on Effectuated Policies

 •   PD645 and PY645 apply when the dispute is for an unexpected
     payment and the issuer did not report the record as cancelled.
 •   PD645 and PY645 modifications are as follows:
     – Previously, PD645 and PY645 applied to disputes where the issuer had not
       sent in an RCNI record for the policy.
     – Going forward, PD645 and PY645 will apply to all disputes of unexpected
       payments where the RCNI did not contain a record or where the record is
       present but does not have an Issuer Initial Premium Paid Indicator of C.
 •   PD645 results in disposition code R6: Dispute Not Supported By RCNI.
 •   PY645 results in disposition code R10: Dispute Not Supported By RCNI
     – Prior Year.
 •   As a result of these changes, ER&R deactivated detail codes PD542,
     PY542, PD621, and PY621.

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Common Errors: Avoiding FV9

•   ER&R has noticed an increase in the number of Payment Disputes
    receiving the FV9 detail code, which results in the disposition code R3:
    FFM Fields on Form do not Match PPR/HIX 820.
•   Disputes are assigned the FV9 detail code when an issuer disputes an
    unexpected or incorrect payment but the PPR/HIX 820 report does not
    contain a record of a payment that matches the disputed data.
•   Most disputes that receive the FV9 detail code have the wrong Payment
    Cycle Month on the dispute.
•   In order to avoid the FV9 detail code, issuers must ensure that the
    Payment Cycle Month on the dispute matches the month in the Policy-
    Based Transition Payment Month field of the PPR file and not the month
    the coverage took place.

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Common Errors: Avoiding FV9 (Cont.)

• Here is an example of a dispute that will receive an FV9 detail code:

       •   Other fields that can result in FV9 detail codes include:
            – HIOS ID
            – Exchange Assigned Policy ID
            – Coverage Period Start Date (FFM)
            – Coverage Period End Date (FFM)

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zONE Publications

•   Disposition and Detail Code List v24 is available on zONE. This version
    includes the new detail codes that were presented in the previous slides.
•   The Combined Enrollment and Payment TRG v8.0 contains updates for
    AM approvals on prior year disputes.
•   UIR TRG v7.0 and UIR Master Guidance contain details regarding the
    UIRY function code.
•   Issuers can review the updated documentation on CMS zONE:
     – https://zone.cms.gov/document/enrollment-resolution-and-reconciliation

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Questions?

  To submit or withdraw questions by phone:
    • Dial *# (star-pound) on your phone’s keypad to ask a
      question.
    • Dial *# (star-pound) on your phone’s keypad to
      withdraw your question.
  To submit questions by webinar:
    • Type your question in the text box under the ‘Q&A’ tab.

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APPENDIX

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ACCESS TO CMSzONE
  Step 1: CMS Secure Portal Registration Process:
 (Pre-requisite to CMSzONE Access)
 1. Register for access at CMS Secure Portal Here: https://portal.cms.gov/
 2.   Click on “New User Registration” under CMS Secure Portal
 3.   Complete information and create User ID and Password

  Step 2: CMS zONE Access Request:
 1.   Log in at https://portal.cms.gov/ with your CMS Secure Portal credentials
 2.   Click on “Request Access Now”
 3.   Scroll down the page to find “zONE” and click on “Request Access”
 4.   Complete information and wait for confirmation email
 5.   Once confirmation email is received, user may log -in to CMSzONE

 Step 3: CMSzONE Private issuer Community Access:
 (After being granted CMS zONE access)
 1.   Log into zONE; click on the Communities tab
 2.   Click Browse Private Communities
 3.   Click Issuer Community – Private
 4.   Click Join Community
 5.   Provide explanation of why you need access to this community; Include:
      ·     name and contact information
      ·     issuer POC contacts
      ·     specific work for issuer (i.e. fill out QHP templates, processing 834’s, etc.)

                                                   User Access Quick Guide
                                                   A copy of the comprehensive User Access Quick Guide is posted on zONE @:
                                                   https://zone.cms.gov/document/zone-end-user-access-quick-guide (pre-log in required to access zONE links)

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Reference Documents

  • SBE Issuer Information page (all of the following documents are available on
    this page): https://zone.cms.gov/wiki/sbm-Issuer-information

  • SBE Issuer ICD: https://zone.cms.gov/document/sbe-Issuer-icd
  • SBE PBP Transition Guide: https://zone.cms.gov/document/sbe-Issuer-
    transition-guide
  • SBE Issuer PBP FAQ: https://zone.cms.gov/document/policy-based-
    payments-transition-faq
  • CSR Operations FAQ: https://zone.cms.gov/document/csr-operations-faq
  • Monthly Batch Cycle Calendars: https://zone.cms.gov/wiki/sbm-Issuer-
    information

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Reference Documents Continued

 • Issuer Dispute Form: https://zone.cms.gov/document/Issuer-dispute-form
 • Enrollment and Payment Files Chart: https://zone.cms.gov/document/sbm-
   pbp-files-chart
 • Managed File Transfers (MFT) Thin Client Help Guide:
   https://www.regtap.info/reg_librarye.php?i=1778
 • CMS Individual Market HIX 820 X12 Scenarios:
   https://zone.cms.gov/document/cms-individual-market-hix-820-x12-
   scenarios
 • Payee Information Report (Function code: PNR) for Payee:
   https://zone.cms.gov/document/payee-information-report
 • Temporary Manual Adjustment Scenarios:
   https://zone.cms.gov/document/temporary-manual-adjustments-scenarios

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Sample Intent to Refer Letter

        Initial Invoice FINAL REQUEST

        Re: Program                :            Advance Payments of the Premium Tax Credit
        Entity ID                  :            A123456
        Invoice Number             :            A1111A011001001
        Invoice Date               :            13-JUL-2018
        Invoice Amount             :            $101.99
        Interest Charge            :            $10.01
        Administrative Fee         :            $15.00
        Total Amount Due           :            $127.00

  •   The Program, Entity ID, Invoice Number, Invoice Date, and Invoice Amount are the same fields transmitted in
      the Initial Invoice.
  •   Interest Charge – The interest charge is the interest owed and is calculated based on the original invoice
      amount, number of months outstanding, and the current interest rate
       •   Interest is assessed on a monthly basis
  •   Administrative Fee – The administrative fee is a fixed fee of $15 that is applied only once when an invoice is
      over 30 days old
  •   Total Amount Due – The total amount due is the sum of the invoice amount, interest charge, and
      administrative fee

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Contacting FMCC

         When contacting the FMCC, issuers
         should include their five (5)-digit Health
         Insurance Oversight System (HIOS) ID
         and their seven (7)-character Payee ID,
         along with their request.

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Acronyms
 Acronym   Definition
 DSH/HUB   Data Services Hub
 EFT       Electronic File Transfer/Electronic FundsTransfer
 EPS       Enrollment and Payment System
 FFE       Federally-facilitated Exchange
 FMCC      Financial Management Coordination Center
 HIOS      Health Insurance Oversight System
 HIX       Health Insurance Exchange
 PBP       Policy-based Payments
 PNR       Payee Information Report
 PPR       Preliminary Payment Report
 PSV       Pipe-separated value
 SBE       State-based Exchange
 SHOP      Small Business Health Options Program

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Resources

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Resources

 Inbound 834 Process (CMS zOne Dedicated Page):
 •    Production Overview, Technical Specifications, Reporting
 •    For further assistance, please contact: Inbound834@bah.com
 Enrollment Reconciliation:
      • For further assistance, please contact:recon_Issuer_support@bah.com
 Dispute submission:
      • Resources
           • Payment dispute form:
              https://zone.cms.gov/system/files/documents/ft_ppr_820_dispute_form_002.xls
              x
           • Combined Enrollment and Payment Dispute Technical Reference Guide:
              https://www.regtap.info/reg_librarye.php?i=2664.
           • For further assistance, please contact the ER&R Support Center at
              errsupportcenter@cognosante.com or (855) 591-7113

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Combined Enrollment and Payment Dispute
Technical Reference Guide

  • The Combined Enrollment and Payment Dispute
    Technical Reference Guide (TRG) provides guidelines for
    issuers regarding how to submit payment disputes.
  • Issuers can access the TRG at the following links:
    • https://www.regtap.info/reg_librarye.php?i=2664
    • https://zone.cms.gov/system/files/documents/combined
       _enrollment_and_payment_disputes_trg_v3.2.docx

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Resources

                   Resource                                     Resource Link
 Centers for Medicare & Medicaid Services            http://www.cms.gov/
 (CMS)
 U.S. Department of Health & Human Services          http://www.hhs.gov/
 (HHS)
 The Center for Consumer Information &               http://www.cms.gov/cciio
 Insurance Oversight (CCIIO) web page

 Consumer website on Health Reform                   http://www.healthcare.gov/
 ASC X12Store                                        http://store.x12.org/store/health-
                                                     insurance-exchanges
 Registration for Technical Assistance Portal        https://www.REGTAP.info
 (REGTAP) - presentations, FAQs

 CMS zONE – reference material                       https://zone.cms.gov

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Inquiry Tracking and Management
System (ITMS)

 Stakeholders can submit inquiries to ITMS at
 https://www.REGTAP.info

  Select “Submit
  an Inquiry” or
  to view
  submitted
  inquiries select
  ‘My Inquiries’
  from My
  Dashboard.

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FAQ Database on REGTAP

                                    The FAQ Database allows users to search
                                    FAQs by FAQ ID, Keyword/Phrase,
                                    Program Area, Primary and Secondary
                                    Categories, Benefit Year, Retired and
                                    Current FAQs, and Publish Date.

FAQ Database is available at
https://www.regtap.info/

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Closing Remarks

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