CMS Notice of Intent to Apply

The Centers for Medicare & Medicaid Services (CMS) Annual Call Letter calendar marks November 13, 2017, as the first due date for the Notice of Intent to Apply. It is expected the Center for Medicare will release a reminder memo this month outlining the details. In general, the agency requires a Notice of Intent to Apply to be submitted when an organization plans on submitting a request for any of the following:

  • Offering a new product type (such as a Medicare Advantage Prescription Drug plan or Prescription Drug Plan)
  • Transitioning an existing non- or partial network Private Fee-for-Service (PFFS) to a full network PFFS
  • Expanding the service area of an existing contract
  • Expanding only an employer-only service area
  • Adding prescription drug benefits to an existing contract for the first time
  • Adding Employer Group Waiver Plan (EGWP) market to an existing individual-only service area for the first time
  • Adding individual market to an existing EGWP-only service area for the first time
  • Adding or expanding the service area of a Special Needs Plan
  • Expanding the service area of an existing Medicare-Medicaid Plan

While organizations will have another opportunity once the final application guidance is released in January, for the most part, those who have properly planned are generally certain by November if they intend to pursue this initiative. Feasibility discussions have occurred to help leadership make that “go/no-go” decision. “Along with feasibility discussions, network analysis to determine adequacy and potential gaps is a critical component to consider as you decide on submitting your Notice of Intent to Apply,” states a colleague on the Operational Performance team. “Those steps will help set up the plan to move forward with their application filing.”

Turning to the application, interested parties have certainly already gone through the draft Part C and Part D applications with a fine-tooth comb to determine what’s new for the coming submission and what isn’t needed. If you haven’t reviewed the documents by now, what’s changed may surprise you.

The Notice of Intent to Apply is due in about a month. If you’ve conducted a feasibility study but are still unsure of what to do, don’t be alarmed. (Well, ok, be a little alarmed, but take a step in the right direction and contact us.) Then, once you have made the decision to pursue an application, ask us for assistance. Gorman Health Group has a proven track record of successful application assistance and support. Going in with a clear understanding of the process and expectations helps you put your organization’s best foot forward in the pursuit of this new endeavor.


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Regan Pennypacker
Regan Pennypacker

Regan is Senior Vice President of Compliance Solutions at Gorman Health Group (GHG). She leads the Compliance Solutions practice, responsible for multidisciplinary projects such as Part C and Part D audits, new applications, marketing material reviews, risk assessments, and training engagements. As a member of this team, she has provided compliance direction and insight on industry best practices to many GHG clients. Regan brings GHG clients 19 years of experience in the healthcare industry. Read more

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