DEPARTMENT OF HEALTH AND 
HUMAN SERVICES Centers for Medicare 
& Medicaid Services 
7500 Security Boulevard, Mail Stop S2-26-12 
Baltimore, MD 21244-1850 
 
 
 
CMCS Informational Bulletin 
 
DATE:  October 2, 2015 
 
FROM:  Vikki Wachino, Acting Director 
  Center for Medicaid and CHIP Services 
 
SUBJECT:  Annual Re-determination of Medicare Part D Low-Income Subsidy Deemed 
Status (Re-deeming) 
 
 
The Centers for Medicare & Medicaid Services (CMS) is now preparing for the annual 
redetermination of Medicare Part D low-income subsidy (LIS) deemed status, also known as re-
deeming. This bulletin is to provide an update on the next steps in the process to ensure that 
states understand the process and their role in ensuring that dual eligible beneficiaries have 
timely, affordable, and comprehensive coverage under the Medicare Part D prescription drug 
benefit. 
 
CMS performs the following tasks to reassign LIS-eligible beneficiaries: 
 
  Identifies beneficiaries whose LIS eligibility will continue in 2016;  
  Identifies which plans in each prescription drug plan (PDP) region have a 2016 premium 
at or below the LIS benchmark for that region (or have volunteered to waive a de minimis 
amount above the benchmark);  
  Identifies non-renewing PDPs and Medicare Advantage (MA) plans;  
  Confirms that beneficiaries are assigned to plans in their region of residence, based on 
State Medicare Modernization Act (MMA) files; and 
  Determines which individuals are subject to reassignment.  In general, we reassign only 
full subsidy individuals who have not chosen a plan on their own in the past.  In the case 
of plan non-renewals, we reassign all individuals with full or partial subsidies.  
 
For your information, detailed guidance and additional information can be found in the following 
documents:  
 
  Section 40.1.5 of Chapter 3 (Eligibility, Enrollment, and Disenrollment) of the Medicare 
Prescription Drug Benefit Manual:  https://www.cms.gov/Medicare/Eligibility-and-
Enrollment/MedicarePresDrugEligEnrol/index.html   
 
  Section 40.1.8 of Chapter 2 (Enrollment and Disenrollment) of the Medicare Managed 
Care Manual: https://www.cms.gov/Medicare/Eligibility-and-
Enrollment/MedicareMangCareEligEnrol/index.html    Page 2  CMCS Informational Bulletin 
  Guidance memorandum entitled 2016 Reassignment of Low-Income Subsidy 
Beneficiaries in Prescription Drug Plans dated September 10, 2015, will be available on 
our website at: https://www.cms.gov/Medicare/Eligibility-and-
Enrollment/LowIncSubMedicarePresCov/Reassignment.html  
 
  Guidance memorandum entitled 2016 Reassignment of Low-Income Subsidy 
Beneficiaries in Terminating Medicare Advantage Plans and Medicare Advantage Plans 
Reducing their Service Areas dated September 11, 2015 will also be available on our 
website at:  https://www.cms.gov/Medicare/Eligibility-and-
Enrollment/LowIncSubMedicarePresCov/Reassignment.html  
 
CMS Notifications to Beneficiaries  
 
As provided in Chapter 3 of the Medicare Prescription Drug Benefit Manual, section 40.1.5 - E, 
PDPs that are losing enrollees to a different PDP sponsor due to the annual reassignment process 
have two options for meeting the requirement to provide current enrollees with the annual notice 
of change (ANOC): 
 
  Mail the standard ANOC by September 30, 2015; or 
 
  Mail the alternative ANOC (see Exhibit 30, Optional Notice for Losing Plan to LIS 
Beneficiaries Re-Assigned to a Different PDP Sponsor (in lieu of Annual Notice of 
Change) in Chapter 3) by November 7, 2015.  This option applies only to those PDP 
sponsors that are losing enrollees to a different PDP sponsor due to the annual 
reassignment process this year and have chosen to send the alternative ANOC document.  
 
In addition, CMS will mail the following notices to affected beneficiaries:  
 
  PDP Reassignment Notice: In late October 2015, CMS will mail blue notices to all LIS 
beneficiaries who will be reassigned to a new PDP because the plan into which they were 
previously auto-enrolled will have a premium above the regional LIS benchmark or their 
current PDP is terminating.  
 
  MA Reassignment Notice: Also in late October 2015, CMS will mail blue notices to all 
LIS beneficiaries enrolled in an MA plan that is terminating or has a service area 
reduction.  These individuals will be assigned to PDPs.  
 
Unless individuals make an election on their own, they will be automatically assigned to 
the plan identified in the notice with a January 1, 2016 effective date. To assist LIS 
beneficiaries in making an election, both of these blue reassignment notices will include a 
list of locally available plans that have no premium liability for people eligible for the full 
premium subsidy in 2016. Beneficiaries can use this information to compare their plan 
options.  Except in plan termination situations, the notice also will inform them of the 
new monthly premium amount, if they stay in their current Part D plan.  
  Page 3  CMCS Informational Bulletin 
  Choosers Notice: In early November, CMS will mail tan notices to LIS beneficiaries 
who are in a PDP in which they will have a premium liability, but are not being 
reassigned by CMS because they actively chose their current plan. CMS refers to these 
beneficiaries as choosers.  Like the blue reassignment notice, the tan choosers notice 
will inform them of the new monthly premium amount for which they will be liable if 
they stay in their current PDP and include a list of PDPs that have no premium liability 
for people eligible for the full premium subsidy in 2016.  
 
  Affordable Care Act (ACA) Formulary Notice: In December, CMS will mail a second 
blue notice to all LIS beneficiaries who will be reassigned to a new PDP.  This includes 
those reassigned in the PDP and MA reassignments processes referenced above.  This 
second notice will identify which drugs in their current drug regimen are covered in the 
2016 plan to which they are being reassigned, and how to request an exception to obtain a 
drug that is not included in the plans formulary. 
 
CMS has created a guide to 2015/2016 mailings sent to consumers from CMS, the Social 
Security Administration, and plans.  This guide summarizes each notices message, explains 
when it will be sent, and includes the color of the paper on which the notice is printed.  This 
guide is available on our Limited Income and Resources webpage at: 
https://www.cms.gov/Medicare/Prescription-Drug-
Coverage/LimitedIncomeandResources/index.html   
 
The model beneficiary letters also will be posted on this webpage (in the LIS Notices and 
Mailings section) as they become available.  
 
State Notification  
 
On or about October 16, 2015, CMS will send two files, if applicable, to each state.  The first 
will list the LIS-eligible individuals in their state who will receive a blue PDP reassignment letter 
and the second file will list the LIS-eligible individuals who will receive a blue MA 
reassignment letter. Customer service representatives at 1-800-MEDICARE will be prepared to 
answer questions about the reassignment process and about beneficiaries full range of options.  
In addition, plan information will be available at Medicare.gov.  
 
The reassignment files that CMS sends to states contains a list of full duals, partial duals, 
Supplemental Security Income (SSI)-only eligible individuals, and approved LIS applicants 
residing in their state who will be receiving blue notices from CMS informing them that they will 
be reassigned.  Individuals that a State Pharmaceutical Assistance Program (SPAP) has requested 
CMS to carve-out of the reassignment process, under the SPAPs authority to enroll on behalf of 
its members, will not be included in this file.  This exclusion will ensure that such beneficiaries 
are reassigned only once.  These reassignments will subsequently appear on the states normal 
MMA response file starting on or after October 12, 2015.  See the attachment for the state 
reassignment file layout. 
 
Thank you for your continued assistance with our efforts to ensure that low-income Medicare 
beneficiaries, including dual eligibles, maintain affordable and comprehensive coverage under  Page 4  CMCS Informational Bulletin 
the Medicare Part D prescription drug benefit.  If you have specific questions about any of this 
information, please contact Steve Ludwig at 410-786-0554, or at Stephen.Ludwig@cms.hhs.gov. 
 
 
 
 
Attachment   
ATTACHMENT  STATE REASSIGNMENT FILE LAYOUT  
 
Exchange Name: SRA (State Response) 
(Where x can be H for header and T for trailer) 
Reassignment State Response Files - Header Record 
 
Data Field   Length  Position  Format  Valid Values  
Header Code   8   1   ... 8   CHAR   SRA for re-assign state 
   notification file.  
Sending Entity   8   9   ...  16   CHAR   CMS   
(CMS + 5 spaces)  
File Creation Date   8   17   ...  24   CHAR   CCYYMMDD  
Date file was created.  
File Control Number   9   25   ...  33   CHAR   Spaces  
Filler   767   34   ...  800   CHAR   Spaces  
Record Length =   800  
 
Data Field   Length  Position  Format  Valid Values  
Record Type   3  1  ...   3  CHAR   DTL  
Beneficiarys Health Insurance  12  4  ...   15  CHAR    
Claim  
Beneficiarys SSN   9  16  ...   24  CHAR   Filled with Spaces if the SSN is 
not present.  
Representative Payee Name   44  25  ...   68  CHAR    
Beneficiarys First Name   12  69  ...   80  CHAR    
Beneficiarys Middle Name   1  81  ...   81  CHAR    
Beneficiarys Last Name   28  82  ...   109  CHAR   Last name starts in position 83 
if a middle initial is present. 
Last names that exceed the 
length will have the last 
characters dropped.  
Beneficiarys Address Line 1   40  110  ...   149  CHAR   Filled with the Address  
Beneficiarys Address Line 2   40  150  ...   189  CHAR   Filled with the Address, if 
available.  
Beneficiarys Address Line 3   40  190  ...   229  CHAR   Filled with the Address, if 
available.  
Beneficiarys Address Line 4   40  230  ...   269  CHAR   Filled with the Address, if 
available.  
Beneficiarys Address Line 5   40  270  ...   309  CHAR   Filled with the Address, if 
available.  
Beneficiarys Address Line 6   40  310  ...   349  CHAR   Filled with the Address, if 
available.  
Beneficiarys City   26  350  ...   375  CHAR   Filled with the City  
Filler   1  376  ...   376  CHAR   Spaces  
Beneficiarys State   2  377  ...   378  CHAR   Filled with the State Code  
Filler   1  379  ...   379  CHAR   Spaces  
Beneficiarys Zip Code   10  380  ...   389  CHAR   Filled with the Zip Code  
Beneficiarys Next Years  50  390  ...   439  CHAR   
Organization Marketing Name  
Beneficiarys Next Years Plan  50  440  ...   489  CHAR    
Name  
Beneficiarys Next Years Plan  18  490  ...   507  CHAR    
Member Services Toll-Free Number    
Data Field   Length  Position  Format  Valid Values  
Beneficiarys Next Years Plan Web  50  508  ...   557  CHAR    
Address  
Beneficiarys LIS Subsidy Co- 1  558  ...   558  CHAR   1 - high co-pay  
Payment Category   2 - low co-pay 
3 - no co-pay 
4 - 15% 
Beneficiarys Next Years Assign  8  559  ...   566  NUMERIC   CCYYMMDD  
Effective Date  
Beneficiarys Part D Premium  3  567  ...   569  CHAR   100, 075, 050, or 025  
Subsidy Percentage  
Beneficiarys PDP Region ID Code   2  570  ...   571  NUMERIC    
Beneficiarys Current Years  50  572  ...   621  CHAR    
Organization Name  
Beneficiarys Current Years Plan  50  622  ...   671  CHAR    
Name  
Beneficiarys Current Years Plan  18  672  ...   689  CHAR    
Member Services Toll-Free Number  
Beneficiarys Current Years Plan  6  690  ...   695  DECIMAL    
Premium Liability  
Filler   8  696  ...   703  NUMERIC   Zero  
Beneficiarys Next Years Contract  5  704  ...   708  CHAR    
Number  
Beneficiarys Next Years PBP  3  709  ...   711  CHAR    
Number  
Beneficiarys Current Years  5  712  ...   716  CHAR    
Contract Number  
Beneficiarys Current Years PBP  3  717  ...   719  CHAR    
Number  
Beneficiarys Next Years Plan  6  720  ...   725  DECIMAL   Used when the premium is 
Premium Liability   increasing, decreasing, or 
remaining the same amount that 
is above the benchmark for the 
following year.  
 
Contains next years premium 
for the current plan. 
Filler   75  726  ...   800  CHAR   Spaces  
Record Length =       800     
   
     
Reassignment State Response Files - Trailer Record 
Data Field   Length   Position   Format   Valid Values  
Trailer Code   8   1   ... 8   CHAR   TRL for re-assign state 
   notification file.  
Sending Entity   8   9   ... 16   CHAR   CMS   
   (CMS + 5 spaces)  
File Creation Date   8   17   ... 24   CHAR   CCYYMMDD  
   Date file was created.  
File Control Number   9   25   ... 33   CHAR   Spaces  
  
Record Count   9   34   ... 42   NUMERIC   Right justified.  
    
Count = Number of detail 
records.  
Filler   758   43   ... 800   CHAR   Spaces  
  
Record Length =   800