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September 8, 2022
CMS Issues Updates to 2023 Part D Member Materials to Reflect IRA Provisions
On September 6, 2022, CMS released its first official guidance regarding the Inflation Reduction Act of 2022 (IRA). Prior to this date, plans were hesitant to make any member material updates until CMS provided clear guidance on how the insulin and vaccine requirements would be represented in their member materials. Not only did CMS provide member material information within this memo, but CMS also provided additional insight into the IRA changes for 2023. Highlights of the additional details include the following:
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Part D Senior Savings (PDSS) Model for 2023 - CMS indicates that this model will continue for 2023 and notes that model participants will need to include the required vaccine language within their materials. Additional guidance for PDSS plans is forthcoming and will address model requirements applicable to plan communications and marketing of the PDSS model benefits and coverage for insulin.
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Insulin Coverage - The Evidence of Coverage (EOC), Annual Notice of Change (ANOC), Part D Formulary, Summary of Benefits (SB) and plan sponsor websites should be updated to include specific language that address what the enrollee pays for “each insulin product covered by our plan.” Note that if the plan offers insulins for less than the maximum $35, then the cost-share amount should be updated to reflect that amount. Searchable formularies should be updated to reflect accurate coverage of applicable covered Part D insulins. There are still outstanding questions as to whether non-formulary insulin approved through the plan’s formulary exception process are considered “covered insulins.”
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Vaccine Coverage - The Evidence of Coverage (EOC), Annual Notice of Change (ANOC), Part D Formulary, Summary of Benefits (SB) and plan sponsor websites should be updated to include specific language that addresses what the enrollee pays for Part D vaccines. Searchable formularies should be updated to reflect accurate coverage of applicable vaccines. Note that under the IRA only covered Part D vaccines licensed under section 351 of the Public Health Service Act for use by adult populations and administered in accordance with recommendations of the Advisory Committee on Immunization Practices of the Centers for Disease Control and Prevention are required to be available to Part D beneficiaries for a $0 cost-share.
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Member Material Corrections - If plans cannot provide updated hard copies of member materials by their original delivery dates, plans should distribute errata, addendums, or notice of formulary change as applicable to “fix inaccurate or inconsistent information or guidance related to coverage of insulin or vaccines.” Plans choosing to issue a correction via an additional communication such as an errata will need to send many of these corrections by November 15, 2022. Plans should review the memo for specific due dates.
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Bid Submissions – CMS was clear that plans should not attempt to adjust their bid or attempt to submit plan benefit package (PBP) updates to reflect the new IRA requirements. CMS indicated additional guidance will be released regarding the coverage of vaccines and insulins.
Although the industry is appreciative of the additional IRA guidance from CMS, questions remain regarding how to implement the IRA provisions. BluePeak will continue to monitor all newly released guidance from CMS, as well as industry feedback, and provide updates as needed.
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