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Tag Archives: Medicare Part D
As a follow up to my last article on the Notice of Intent to Apply, I give you an enhanced chart of 2019 application activities outlining things you should have been doing or should be in the middle of now. Thanks to the Centers for Medicare & Medicaid Services (CMS) for creating a base, published recently via memo – my colorful additions peppered throughout for your perusal. If past activities have not been done yet, it is time to get a move on, or you risk missing the deadline. Read more
The Centers for Medicare & Medicaid Services (CMS) Annual Call Letter calendar marks November 13, 2017, as the first due date for the Notice of Intent to Apply. It is expected the Center for Medicare will release a reminder memo this month outlining the details. In general, the agency requires a Notice of Intent to Apply to be submitted when an organization plans on submitting a request for any of the following: Read more
A little section in the Medicare Access and CHIP Reauthorization Act (MACRA) is bringing big changes to Medicare supplemental insurance, also known as Medigap, bought by more than 12 million seniors to help fill in the coverage holes in traditional Medicare. In the vast majority of cases, Medigap purchasers augment their coverage with a Medicare Part D Prescription Drug Plan (PDP). That means MACRA’s changes will cause a seismic event in senior markets – Medicare Advantage, Medigap insurers, and PDPs – nationally, starting now.
Program audits and oversight activities must be designed with many factors to balance: accuracy, consistency, efficiency, and in an effort to be least disruptive to a plan sponsor. Correspondingly, a plan should be tailoring its response to these audits with those same factors in mind. My colleague Deb Devereaux and I outline ten common risk areas we observe in plans large and small. Read more
Is it me, or is time flying by? Applications are done, bids are in, new plans are in planning stages, and existing plans are getting ready for the launch of the next benefit year.
Top of mind when we are talking about Medicare compliance should be that the ultimate customer is the taxpayer who funds this program. That’s why the Centers for Medicare & Medicaid Services (CMS) has to attempt to account for every nickel that comes into or goes out of the programs. One of the murkiest finance areas is in Medicare Part D – that is Direct and Indirect Remuneration (DIR). CMS published a memo on January 19, 2017, with this very title.¹ DIR is the additional compensation – besides a partially capitated payment from CMS – received by a plan sponsor or Pharmacy Benefit Manager (PBM) after the pharmacy point of sale (POS) transaction. This changes the final cost of the drug for the plan sponsor or the price of the drug paid to the pharmacy. DIR has grown significantly in the past few years in large part because of the growth of preferred network pharmacies. CMS states they have observed “a growing disparity between gross Part D drug costs, calculated based on costs of drugs at the POS, and net Part D drug costs, which account for all DIR.”