Tag Archives: Part D

Medicare And Prescription Changes

A lot is happening in the Rx Market this year.  In case you missed it, Aetna has been purchased by CVS health, which has been approved by the DOJ.  As part of this purchase, however, they have to sell Silverscript, the Medicare Rx Program.  This is set to happen around the first of the year, to WellCare.  In the meantime, Silverscripts prices have gone up and Aetna looks much more competitive, and we expect a lot of changes this year.

Walgreens bought Rite Aid and is in the process of consolidating stores and plans.  No word yet on what will happen to Rite Aids’ Envision Rx program, and Walgreens has maintained its deal with AARP.

It is important that Seniors check their prescriptions EVERY year, as this is the time of year when everything changes.  It is too late to change in January when you discover your medication is no longer covered!

 

 

Part D Prescription plan changes

On Thursday, August 30, the Centers for Medicare & Medicaid Services (CMS) issued two guidance documents to provide clarification to plans participating in the Medicare Part D prescription drug program.

  • Step therapy and Part B drugs: CMS recently announced Part D plans would be permitted to establish “step therapy” programs for Part B drugs starting in 2019. However, CMS’s announcement raised many questions for Part D plans considering participation in this program in 2019. A new Q&A attempts to answer those questions.
  • Indication-based formularies: CMS also released separate guidance that permits Part D plans to develop “indication-based” formularies starting in 2020. Many medications have multiple uses. However, Medicare rules currently require Part D plans to cover a prescription drug without differentiating the conditions for which it is most appropriate. The new rules would change that starting in 2020.

These guidance documents reflect the Trump Administration’s continued interest in reducing prescription drug costs. We expect CMS to announce additional actions in the next several weeks.

Reminder – Medicare Part D Employer Notification Requirements

 

Published: Thursday, September 7, 2017 Updated: Friday, September 22, 2017

Update 09/22/17: The Medicare and You 2018 handbook is now available.
The 2018 Annual Election Period (AEP) for Medicare Part D begins October 15, 2017 and ends December 7, 2017.
The Medicare Modernization Act of 2006 provides access to prescription drug coverage to all Medicare-eligible persons under Medicare Part D. Plan sponsor notice regarding the organization’s prescription benefits must be provided to any Medicare-eligible person whether due to age or disability and is required for employees, spouses, dependents, those on Federal COBRA or New York, New Jersey, Pennsylvania, and Delaware continuation including retirees. Notice must be provided before Open Enrollment begins.
Employees will use that information to help them formulate their personal decision of whether or not they will enroll in Medicare Part D prescription coverage outside of the employer plan. This decision is critical as penalties apply when Part D is not timely in place.
Medical insurance carriers typically notify policyholders regarding the Creditable versus Non-Creditable status of the prescription coverage plan. It is the plan sponsors’ (typically the employer) responsibility to notify their groups’ members.
Please keep in mind that this determination is the employer’s responsibility when the employer is the plan sponsor. If the carrier states that the health plan is non-creditable, the benefits may still be creditable if the employer has an HRA arrangement. The employer would have to override the carrier notice. Therefore, it is the employer’s responsibility to examine all of the benefits that the employer is providing and determine the creditability of the prescription coverage. The carrier is only providing notification regarding the creditability of the coverage that the carrier provides.
In an effort to assist you when consulting with our mutual clients, Savoy has prepared a sample employer education package which you may use to communicate notification obligations to your employer plan sponsors.
This package contains the following:

  1. Letter from Broker Advising the Employer of Notification Responsibility
  2. Medicare and You 2018 Handbook
  3. Sample Personalized Employee Letters for Notification of Creditable and Non-Creditable Coverage:

Note: These Model Notices were issued for use on or after April 1, 2011 and are still current. Spanish versions are available at cms.hhs.gov.
Creditable Coverage Disclosure to Centers for Medicare and Medicaid Services (CMS)   Most entities that currently provide prescription drug coverage to Medicare D eligible individuals (including employees, dependents, continuees, and those eligible for Medicare due to age or disability) must disclose to CMS whether or not the coverage is a creditable prescription drug coverage. The disclosure must be provided whether the entity is primary or secondary to Medicare.
Group plan sponsors should click HERE to complete the Creditable Coverage Disclosure to CMS Form online.
During the Annual Election Period (AEP), clients may also make changes to various aspects of their coverage.

  • Switch from Original Medicare to Medicare Advantage, or vice versa.
  • Switch from one Medicare Advantage plan to another, or from one Medicare Part D (prescription drug) plan to another.
  • If they did not enroll in a Medicare Part D plan when first eligible, they can do so during the general Open Enrollment Period, although a late enrollment penalty may apply.

To enroll in a Medicare Advantage plan, some basic criteria must be satisfied:

  • Must be enrolled in Medicare Part A and B.
  • Must live in the plan’s service area.
  • Cannot have End-Stage Renal Disease (some exceptions apply).

Is auto-renewal available? For those already enrolled in a Medicare Part D or Medicare Advantage Plan who do not want to make changes to their coverage for 2018, they do not need to do anything during AEP, assuming the current plan will still be available in 2018. If the plan is being discontinued and is not eligible for renewal, they will receive a non-renewal notice from the carrier prior to AEP. These individuals will have an extended enrollment period through February 28, 2018.

Annual Medicare Part D Notification Requirements

Every year groups are required to notify anyone that is Medicare-eligible regarding if the prescription plan they provide meets Medicare Creditable Coverage requirements.

Language from the notification memo from CMS is below.

Notification needs to go to Medicare eligible members by October 15th.  Additionally, you must go the CMS site each year and report on your plan.  Use the link below for more information and helpful links.

Here is the CMS notice in part:

Reminder – Medicare Part D Employer Notification Requirements

Update 09/22/17: The Medicare and You 2018 handbook is now available.
The 2018 Annual Election Period (AEP) for Medicare Part D begins October 15, 2017 and ends December 7, 2017.
The Medicare Modernization Act of 2006 provides access to prescription drug coverage to all Medicare-eligible persons under Medicare Part D. Plan sponsor notice regarding the organization’s prescription benefits must be provided to any Medicare-eligible person whether due to age or disability and is required for employees, spouses, dependents, those on Federal COBRA or New York, New Jersey, Pennsylvania, and Delaware continuation including retirees. Notice must be provided before Open Enrollment begins.

Employees will use that information to help them formulate their personal decision of whether or not they will enroll in Medicare Part D prescription coverage outside of the employer plan. This decision is critical as penalties apply when Part D is not timely in place.
Medical insurance carriers typically notify policyholders regarding the Creditable versus Non-Creditable status of the prescription coverage plan. It is the plan sponsors’ (typically the employer) responsibility to notify their groups’ members.

Please keep in mind that this determination is the employer’s responsibility when the employer is the plan sponsor. If the carrier states that the health plan is non-creditable, the benefits may still be creditable if the employer has an HRA arrangement. The employer would have to override the carrier notice. Therefore, it is the employer’s responsibility to examine all of the benefits that the employer is providing and determine the creditability of the prescription coverage. The carrier is only providing notification regarding the creditability of the coverage that the carrier provides.

Medicare Part D Notices required by 10/14

Each year, Medicare Part D requires group health plan sponsors to disclose to individuals who are eligible for Medicare Part D and to the Centers for Medicare and Medicaid Services (CMS) whether the health plan’s prescription drug coverage is creditable. Plan sponsors must provide the annual disclosure notice to Medicare-eligible individuals before Oct. 15, 2016-the start date of the annual enrollment period for Medicare Part D. CMS has provided model disclosure notices for employers to use.

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Reeve Conover is a Registered Representative. Securities offered through Cambridge Investment Research, Inc., a Broker/dealer member FINRA/SPIC. Cambridge and Conover Consulting are not affiliated. Licensed in SC, NC, NY, CT, NJ, and CA.
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