Comment 3

MN950-1000
P O Box 9472
Minneapolis MN 55440-9472

To:

Centers for Medicare and Medicaid Services
Center for Beneficiary Choices
500 Security Boulevard
Baltimore, MD 21244-1850
Submitted via email to: PartDAppcomments@cms.hhs.gov

From: Teena Ballard Keiser, Director of Regulatory Affairs
Date: November 20, 2006
Re:

Draft 2008 Prescription Drug Plan Applications

We have reviewed the Draft 2008 Prescription Drug Plan Applications and provide the
following attached comments. These comments are provided on behalf of Ovations and
other UnitedHealth Group affiliates that manage Medicare Advantage and Part D
business (collectively “United”). Please note that, for the purposes of this letter, “United”
includes the Ovations business units that manage the combined PacifiCare and Ovations
legacy Part D business.
Attached to this memo are comments from Ovations that are particularly significant to us
on the Draft Part D Applications. Our comments are related to the following
applications:
¾ Draft 2008 Solicitation for New Medicare Advantage-Prescription Drug Plan
(MA-PD) Sponsors
¾ Draft 2008 Solicitation for Applications for New Prescription Drug Plan (PDP)
Sponsors
We greatly appreciate the opportunity to comment, and we look forward to continuing to
work with CMS to develop successful products and services for Medicare beneficiaries.
If you have any questions or concerns on our comments, please contact me at 507/6631844 or via email teena_keiser@uhc.com.

UnitedHealth Group/Ovations
November 20, 2006

Draft 2008 Prescription Drug Plan Applications
1 of 2

Draft 2008 Prescription Drug Plan Applications
Comments Submitted by
UnitedHealth Group/Ovations
November 20, 2006
We would like to begin our comments by noting our appreciation for all the work CMS
has done and is doing to reduce the amount of paperwork associated with these
applications. Specifically, by now requiring the attestations for both the Initial
Application and Service Area Expansions to be entered in HPMS rather than being
submitted in the binder(s).
Draft Solicitation for Applications for New Medicare Advantage Prescription Drug
Plan (MA-PD) Sponsors

1.

Section 3.4 B #7:
Issue: Item #7 states that the "Applicant agrees to maintain a contract log as
specific in forthcoming CMS guidance."
Recommendation: We recommend that CMS provide the
opportunity for the MA-PD sponsors to review and comment on this guidance in
draft form before it is finalized. In addition, we would recommend that the log
requirement be on a prospective basis not a retrospective basis."

Draft 2007 Solicitation for Applications for New Prescription Drug Plan (PDP)
Sponsors
2.

Section 3.4 A #7:

Issue: Item #7 states that the "Applicant agrees to maintain a contract log as
specific in forthcoming CMS guidance."
Recommendation: We recommend that CMS provide the
opportunity for the PDP sponsors to review and comment on this guidance in
draft form before it is finalized. In addition, we would recommend that the log
requirement be on a prospective basis not a retrospective basis."

UnitedHealth Group/Ovations
November 20, 2006

Draft 2008 Prescription Drug Plan Applications
2 of 2