I got a response from the author Bill Dacey, below is the response I got.
"Hi Laura - thanks for writing. I looked at what I had written - and either I wrote it incorrectly or it was edited a bit - could easily have been me.
CMS central has not said that. Various carriers have said it in various ways. Not only have carrier medical directors and policy managers stated that, but when you look at their guidelines you can see it.
I'm going to attach one of those guidelines - from Trailblazer. Look at the table A1. The first and subsequent options indicate different weights relative to how management is documented, how many drugs are managed. I'll also include an interim version of one of the AMA Tables of Risk - that places certain Rx management at level 3.
You are correct though - 'CMS' didn't say that - but their agents do"
I can't post the attachments but if anyone is interested in them let me know and I can email them.
Laura, CPC, CEMC