CMS Guidance on Medicare Part D Coverage Gap Discount Program, Cost-Sharing for Dual Eligibles
CMS has provided updated information on certain Medicare Part D Coverage Gap Discount Program issues. Specifically, in an October 28, 2011 memo to plan sponsors and drug manufacturers, CMS discusses its policies regarding invoicing manufacturers for certain low-volume claims, Electronic Fund Transfer requirements for discount payments, and changes to the appeals timeline after an unfavorable third party administrator determination or expiration of the dispute resolution timeframe. Separately, CMS has issued a memo to states on implementation of section 3309 of the ACA, which eliminates Part D cost-sharing for full benefit dual eligible individuals receiving home and community-based services, effective January 1, 2012. The CMS memo discusses the data that CMS needs from states regarding eligible individuals, and the process for beneficiaries to correct HBCS status.
