CMS Releases Final 2008 "Call Letter" For Medicare Advantage and Medicare Part D

04/20/2007

On Thursday, April 19, 2007, the Centers for Medicare and Medicaid Services (CMS) released the final version of the 2008 Call Letter, the agency’s guidance on the Medicare Advantage and Medicare Prescription Drug (Part D) programs for the 2008 benefit year.

The Final Call Letter is generally very similar to the draft version released in March 2007. A few notable points from the Final Call Letter are as follows:

In response to the "extensive and quite thoughtful nature" of comments addressing vaccine administration reimbursement, CMS is "taking additional time" to finalize its operational guidance. The agency expects to release this detailed guidance in May 2007, in time for Part D Plan Sponsors to make appropriate allowances for their Contract Year 2008 bid submissions.

CMS received "a significant negative response" to its proposal to allow a Plan to create a comparison of competing Plans within its service area, based on comparison data obtained from Medicare Options Compare. Persuaded that such comparisons would not be "practical or meaningful," CMS withdrew the proposal in the Final Call Letter.

CMS left unchanged its discussion regarding the development of Medicare Advantage reporting requirements, including the expectation that Medicare Advantage Plans will be required to "collect and self-report information beginning in 2008." CMS’ identified "areas of interest," also unchanged from the draft Call Letter, include "sales and marketing violations…security breaches…and financial viability."

The Final Call Letter is available on CMS’ website at: http://www.cms.hhs.gov/PrescriptionDrugCovContra/Downloads/CallLetter.pdf

McDermott Will & Emery

McDermott Will and Emery