CMS Releases Draft "Call Letter" for Medicare Advantage and Medicare Part D

01/17/2008

The Centers for Medicare and Medicaid Services (CMS) released today its draft for the 2009 Call Letter, which is the agency’s guidance on the Medicare Advantage and Medicare Prescription Drug (Part D) Programs for the 2009 benefit year.  Comments to the draft Call Letter are due to CMS by 5:00 pm on January 30, 2008.

The Call Letter sets out reminders about important operational issues as well as new policies and requirements relating to the Medicare Advantage and Part D Programs.  The following are some of the issues discussed in the Call Letter:

  • The Call Letter addresses CMS’s new guidance for standardization of prior authorization requirements under Medicare Part D, including publication of the requirements on Plan websites.
  • The Call Letter imposes a new requirement that Part D Plan Sponsors charge Members at the point-of-sale the lesser of the co-payment or the negotiated price of the drug, even when the Member is within the coverage gap.
  • CMS is developing a set of reporting requirements for Medicare Advantage Organizations.
  • The Call Letter describes CMS’s expectation that Medicare Advantage Private Fee For Service Plans (PFFS) be “proactive and not reactive” in addressing compliance issues.  Sponsors of PFFS Plans also should “strive to ensure” that their payment terms and conditions are easily accessible and that providers are paid timely and correctly.

The draft Call Letter is available on CMS’s website.

McDermott Will & Emery

McDermott Will and Emery