AEP CY 2025: Medicare Part D Pharmacy Network Access Analysis

Relevant to: PDP, Part D

Each week, we scan the latest CMS memos to find the most important ones that apply for PACE programs. Below is a summary of what you need to know.

Disclaimer: The content provided on this site is a summary for informational purposes only, and Grane PBM, Inc. assumes no liability for any errors or omissions in the site’s content. The information does not constitute legal or regulatory advice or replace the original CMS memo. Readers are advised to consult the CMS memo in its entirety and to verify information independently before making any decisions based on this information.

Read the full memo from CMS here.

Introduction

The Centers for Medicare & Medicaid Services has released the analysis results for Retail Pharmacy Network Access and Preferred Cost-Sharing Pharmacy Access for AEP CY 2025. This data, available in HPMS, assesses whether sponsors meet the required retail pharmacy access standards. Plans falling short may face compliance or enforcement actions, necessitating immediate review by sponsors to avoid potential penalties.

Key Dates and Deadlines

The following are important dates related to the memo on Retail Pharmacy Network Access and Preferred Cost-Sharing Pharmacy Access Analysis Results for AEP CY 2025:

  • Memo Date: December 2, 2024
  • Deadline for Questions or Concerns: December 16, 2024

PACE Compliance

This memo is relevant to PACE programs because it addresses the compliance requirements related to retail pharmacy network access. The analysis results for the Annual Enrollment Period (AEP) Contract Year (CY) 2025 have been released, which are crucial for ensuring adherence to specific access standards.

PACE participants must ensure they meet the retail pharmacy access standard as mandated by 42 C.F.R. § 423.120(a)(1). In cases where plans do not meet these standards, they may be subject to compliance or enforcement actions by CMS. Therefore, it is essential for PACE programs to review the available data in the Health Plan Management System (HPMS) and address any potential access issues.

Required Actions

The data from CMS’s retail pharmacy access analyses for AEP CY 2025 are now available in HPMS for review. To access the Part D retail access data in HPMS, please follow this path: Quality and Performance > Performance Metrics > Reports > Retail Pharmacy Network Access Data > select report period. CMS will use the analysis to identify sponsors’ plans that are not meeting the retail pharmacy access standard required by 42 C.F.R. § 423.120(a)(1). Sponsors identified as access outliers may receive compliance or enforcement actions. For questions or concerns about your plan data please contact PartD_Monitoring@cms.hhs.gov by December 16, 2024.

FAQs

  • “What is retail pharmacy network access analysis?”
  • “How can I access Part D retail access data on HPMS?”
  • “What actions might CMS take if a plan does not meet access standards?”
  • “Who should be contacted for questions about plan data?”

Read the full memo from CMS here.

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