Crosswalk

Crosswalk
Old version

New Version

Old verbiage: Compliance for
prescriptions in long-term care
settings begins in CY 2025.

Updated verbiage: Compliance for
prescriptions in long-term care
settings begins in CY 2028.

We estimated only 100 waiver
applications per year, due to that it
was a new portal application and
new PRA package, and we had no
prior number to base the estimate
on.

Updated the volume of waiver
applications based on first year
collection: we received a total of
278 waivers applications, and we
will use the assumption of a 10%
increase per year for a total of 306
waivers for this calculation.

Reason for change

Rev

Rev

Burden
Change

Change in rule to give long term care No
prescribing more time to update their
systems to match the requirement of
a new e-prescribing standard.

Revised based on OMB instruction to
“monitor the number/volume of the
waiver applications”. Updated the
volume of waiver applications based
on first year collection. We expect to
see an increase in the number of
waiver applications based on the
numbers from the previous year as
well as factoring in a 10% increase.

Type of Change: Rev = Revision, Del = Deletion, Add = Addition, and Red = Redesignation

No burden
change to the
individual persons
filling out their
waiver
applications.

Crosswalk
Old version

New Version

Reason for change

Burden
Change

In the waiver application, for
categories of circumstances beyond
control that prevented the
prescriber from meeting the
compliance, there were 3 check box
categories: 1) Economic Hardship
2) Technological Limitation and 3)
Others.

In the newer version, the 1)
Economic Hardship is changed to
1) Software Limitations. We also
added a new category of 3) Local
disaster or emergency. And the
category “Others” become the 4)th
category.

Rev

Revised based on OMB instruction
that “CMS monitors the number and
types of waiver applications. Based
on the volume and merits of the
waiver application, revise… and/or
information collected the waiver
application.” We reviewed the waiver
applications received in the first year
and revised the categories of
circumstances collected in the waiver
application.

Reduced the
burden for waiver
applicants some
verbiage on
describing the
general category
of their
circumstances.

No instruction or criteria for the
waiver application in the previous
version.

Added instructions and criteria for
application that are 1) the colored
box tables summarizing prescriber
compliance status 2) verbiage
around the colored box tables that
only the non-compliant can apply
for the waiver.

Rev

Revised based on OMB instruction
during previous approval to “…revise
the instructions, criteria for
application, and/or…”. We added
instructions and the criteria for
application using the colored box
tables and the associated verbiage
instructions.

Reduced burden
by showing
prescriber
compliance status
in concise table
and clarifying that
those compliant
do not need to
submit waiver
applications.

Type of Change: Rev = Revision, Del = Deletion, Add = Addition, and Red = Redesignation

Crosswalk
Old version

Only one NPI (National Provider
Identifier) can be checked per time
for compliance status and for
submitting a waiver application.

New Version

Revised to multi-NPI check feature
that can check single as well as
multiple NPIs’ compliance statuses
and submitting multiple waiver
applications per time.

Reason for change

Rev

Prescriber staff and organization
staff feedback on the burden for
checking multiple prescribers’
statuses when only one NPI can be
checked for compliance status per
time and one waiver application can
be submitted per time.

Type of Change: Rev = Revision, Del = Deletion, Add = Addition, and Red = Redesignation

Burden
Change

Reduced the
burden for the
administrative
staff by
implementing a
multiple-NPI
check feature that
would check
multiple
prescribers’
compliances and
apply for multiple
waivers in one go