Medicare Prescription Payment Plan FAQs: 2025 Updates for Part D Sponsors
Relevant to: TrOOP, COB, 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.
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Introduction
The Centers for Medicare & Medicaid Services (CMS) has released an update to the Frequently Asked Questions (FAQs) regarding the Medicare Prescription Payment Plan. This crucial update assists Part D sponsors in preparing for the plan’s implementation on January 1, 2025. The plan offers participants the ability to spread out-of-pocket prescription drug costs into manageable monthly payments instead of paying at the point of sale. The updated FAQs also bring clarifications and additional guidance to help navigate these upcoming changes.
Key Dates and Deadlines
- Part D sponsors are required to implement the Medicare Prescription Payment Plan starting January 1, 2025.
- Final part one guidance for the Medicare Prescription Payment Plan was issued on February 29, 2024.
- Final part two guidance for the Medicare Prescription Payment Plan was issued on July 16, 2024.
- Original FAQ document released on October 1, 2024.
- Annual Election Period begins October 15, 2024.
PACE Compliance
This memo is relevant to PACE programs because it addresses the implementation of the Medicare Prescription Payment Plan, effective January 1, 2025, which requires Part D sponsors to offer enrollees the option to pay out-of-pocket prescription drug costs in monthly installments. PACE programs, like other Part D sponsors, need to comply with these guidelines to ensure beneficiaries have access to the same payment options.
Plans must:
- Adhere to the guidance provided to allow enrollees, including those under PACE, to opt for monthly payment plans for prescription drugs.
- Maintain coordination with charitable programs such as SPAPs and ADAPs, ensuring they can contribute towards participants’ out-of-pocket costs without interference from the new payment plan rules.
- Ensure that the proper claim processing order is followed by using the BIN/PCN transaction to capture final payments after all other coverages have been applied.
- Provide timely notification of acceptance or denial of request to participate in the Medicare Prescription Payment Plan.
By following the outlined procedures, especially regarding claims processing and participant communication, PACE organizations can ensure compliance with the new CMS requirements.
Required Actions
CONTENT TO USE FOR GENERATION: mailto:MedicarePrescriptionPaymentPlan@cms.hhs.gov
DEPARTMENT OF HEALTH & HUMAN SERVICES Centers for Medicare & Medicaid Services 7500 Security Boulevard Baltimore, Maryland 21244-1850
CENTER FOR MEDICARE
DATE: November 15, 2024 TO: All Part D Sponsors FROM: Jennifer R. Shapiro, Director, Medicare Plan Payment Group
SUBJECT: Update to Frequently Asked Questions related to the Medicare Prescription Payment Plan
CMS has developed FAQs to aid Part D sponsors in preparing for the 2025 implementation of the Medicare Prescription Payment Plan. The FAQs address final guidance and updates.
1. Ensure all employees are aware of the new policy and familiar with the FAQ document to assist enrollees effectively.
2. Review and integrate the new guidelines and FAQ clarifications into your current operating procedures and outreach communications.
3. Establish a system to receive and respond to inquiries related to the Medicare Prescription Payment Plan through email or other designated support channels.
Please direct any questions to MedicarePrescriptionPaymentPlan@cms.hhs.gov.
FAQs
- “What is the Medicare Prescription Payment Plan and when will it be implemented?”
- “Can a Part D enrollee in the Medicare Prescription Payment Plan receive charitable assistance for out-of-pocket costs?”
- “How can Part D enrollees elect to participate in the Medicare Prescription Payment Plan?”
- “What are the requirements for notifying enrollees about their election status in the Medicare Prescription Payment Plan?”
- “Are drugs covered by Pharmaceutical Manufacturer Patient Assistance Programs eligible for the Medicare Prescription Payment Plan?”
