Medicare Part D Update
February 12, 2009
Jonathan E. "Jon" Anderman- Boston
Tracking Important Developments Affecting the Medicare Prescription Drug Benefit Program
Medicare Improvements for Patients and Providers Act (MIPPA)
The recently enacted MIPPA implements a variety of substantial changes in the health care industry. Some of the key provisions relevant to Medicare Part D include:
E-Prescribing: encouraging physicians to prescribe electronically by allowing an increase in payments for professional services starting at 2 percent in 2009 and phasing down to 0.5 percent in 2013; and, penalizing physicians who do not prescribe electronically by reducing payments to 99 percent in 2012 and phasing down to 98 percent in 2014 and subsequent years
Prompt Pay: requiring Part D plan sponsors to pay electronic claims within 14 days and paper claims within 30 days of receipt from pharmacies, or suffer a financial penalty
Marketing: increasing regulatory requirements and prohibitions on marketing by Medicare Advantage Organizations and Part D plan sponsors
2009 CMS Call Letter – Limiting Copayments to Negotiated Price
The 2009 CMS Call Letter for Medicare Advantage (MA), Medicare Advantage-Prescription Drug (MA-PD), Cost-Based Plan, and Stand Alone Prescription Drug Plan (PDP) discusses CMS’ plans to implement, revise, and expand regulations relevant to these organizations in the upcoming year. One noteworthy section discusses new limits on beneficiary copayments to a Part D plan. Previously, Part D sponsors could apply either a copayment or the actual negotiated price. The new policy will remove this option and require Part D plan sponsors to amend their payment systems to charge beneficiaries the lesser of a drug’s negotiated price or the applicable copayment amount. Thus, Part D plans no longer will be able to benefit financially from the difference between the copayment amount and the negotiated price.
For more information, contact:
Jonathan Anderman
617.305.2162
jonathan.anderman@hklaw.com
toll free: 1.888.688.8500
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