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MedPAC comments on CMS's proposed rule on Medicare Part C and Part D

Jan 05, 2018
The Bottom Line

On January 3, 2018, MedPAC commented on CMS’ proposed rule for Medicare Part C and Medicare Part D. The proposed rule includes provisions that would revise regulations for both the Medicare Advantage program (Part C) and the Prescription Drug Benefit program (Part D). MedPAC’s comments focus on the following provisions:

•Flexibility in the Medicare Advantage (MA) uniformity requirements

•Meaningful differences in MA bid submissions and bid review

•Coordination of enrollment and disenrollment through MA organizations and effective dates of coverage and changes of coverage

•Passive enrollment flexibilities to protect continuity of integrated care for dually eligible beneficiaries

•Establishing limitations for the Part D Special Election Period (SEP) for dually eligible beneficiaries 

•MA and Part D Prescription Drug Plan (PDP) quality rating system

•Changes to the days’ supply required by the Part D transition process

•Expedited substitutions of certain generics and other midyear formulary changes

•Treatment of follow-on biological products as generics for non-low-income subsidy (LIS) catastrophic and LIS cost sharing

•Eliminating the requirement to provide PDP Enhanced Alternative (EA) offerings with meaningful differences

•Request for information regarding the application of manufacturer rebates and pharmacy price concessions to drug prices at the point of sale

•Lengthening adjudication timeframes for Part D payment redeterminations and independent review entity (IRE) reconsiderations

•Removal of Quality Improvement Project (QIP) for MA organizations Flexibility in the MA Uniformity Require

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