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Immediate Updates to the Timeliness Monitoring Project (TMP)

On June 28, 2021, CMS announced that the Timeliness Monitoring Project (TMP) will be moving from the 1Q of the subsequent year to the 3Q of the current calendar year.

MA plans need to immediately shift to prioritize TMP activities in parallel to AEP readiness activities.

Plans that had or are currently undergoing a Program Audit in 2021 may be exempt from the reporting if they did not have an Organization Determinations, Appeals and Grievances (ODAG) universe with an Invalid Data Submission (IDS) condition, and the submissions included at least one month of 2021 data for the TMP universe tables. CMS also confirmed they will use the 2020 audit protocols for the TMP.

Sponsors should plan for the following activities:

  • By 8/2/21: Email and provide the status of your organization's SFTP access.

  • Aug 2021: Confirm and update HPMS plan contacts.

  • Sep-Oct 2021: Monitor emails from for instructions on SFTP data submissions and the timeframe being tested.

  • Oct-Nov 2021: Be prepared for validation webinars from the CMS TMP contractors.

  • w/in 10 days: Be prepared to submit the requested TMP ODAG Tables 5-7 within 10 business days of the TMP audit email request form CMS.

How can you create a plan for success? In addition to creating a plan based on the activities above, other important considerations include:

Practice generating the TMP submission now for the January – March 2021* claims and appeals:

  1. Have the business team(s) validate the accuracy and completion of the reports based on other internal operational reports and the CMS technical specifications.

  2. Have the compliance team scrub the file for outliers, anomalies, and non-compliant records.

  3. Hold an internal working session to review the compliance records to determine if the sample is as reliable and valid as possible.

  4. Correct the core systems, data extract logic and data submission as needed.

Prioritize with other activities:

  1. Identify staff accountable for the readiness as well as the validation webinar; and

  2. Ensure your organization is managing the implementing the 2021 audit protocols for 1Q22 while maintaining the integrity of the 2020 audit protocols for ODAG tables 5-7 to support the TMP.

As CMS reminds us: results “…may have implications for the Star Ratings data integrity reviews for the two appeal measures”.

Need help? Contact our experts with planning, preparation, or validation.


*Sponsors with a total enrollment (across all contracts subject to this monitoring project) over 250,000 enrollees will submit January 2021 data, sponsors with an enrollment of 50,000 to 250,000 enrollees will submit (January and February data, and sponsors with an enrollment of less than 50,000 enrollees will submit January, February, and March 2021 data.


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