CMS Pub. 100-18, ch. 12, App. III

Starting in contract year (CY) 2008, Part D entities that offer employer/union-only group

waiver plans (EGWPs) were no longer required to complete Part D Bid Pricing Tool (BPT)

submissions. See 2008 Employer Group Waiver Policy – Elimination of the Requirement for

Entities Offering EGWPs to Submit Part D Bids, February 28, 2007. This waiver policy has

been extended to CY 2009. As noted in the memo, this waiver policy applies to all MA, PDP,

and 1876 Cost organizations offering Part D EGWPs (i.e., “800 series” EGWPs) as well as to

employers/unions that directly contract with CMS to offer Part D benefits to their retirees (i.e.,

“Direct Contract” EGWPs).

NOTE: CMS’ employer group waiver authority applies only to Part D, not to Parts A or B of

the Cost Plan. Thus, section 1876 Cost Plan sponsors may only offer “800 series” Part D

coverage as an optional supplemental benefit and may not offer customized “800 series” A/B

benefits.

CMS has also modified the corresponding Plan Benefit Package (PBP) submission

requirement for all EGWPs offering Part D.

The following table outlines the HPMS PBP and BPT submission requirements for each type

of Part D EGWP for the 2009 contract year:

A B

PBP Section/BPT MA-PD “800 series”

EGWP and Direct

Contract MA-PD EGWP

PDP and 1876 Cost

“800 series” EGWP

and Direct Contract

PDP EGWP

PBP Section A Yes Yes

PBP Sections B, C, and D Yes No

PBP Rx Section No No

MA BPT Yes No

PD BPT No No

Plans that fall under column A will download and install the 2009 PBP software, create their

2009 plans, and download their plan-specific data into the software, per the usual process.

Column A plans will complete sections A, B, C, and D of the 2009 PBP software, but the Rx

Section of the PBP will be disabled. Column A plans will also complete the MA BPT.

Plans that fall under column B will download and install the 2009 PBP software, create their

2009 plans, and download their plan-specific data into the software, per the usual process.

While no actual data entry is required in Section A of the PBP for PDP plan types, plans are

still required to open Section A, review the plan information, and exit Section A with

validation.

All plans outlined in column A and B are required to upload their plans into HPMS, per the

usual process. In addition, these plans are still required to meet all applicable pre-upload

submission requirements to upload plans into HPMS.

NOTE: Plans that fall under column B are required to complete the upload process as a

mechanism for establishing their official set of plan IDs for the 2009 contract year in HPMS.