Medicare Part D: Selected Issues for Plan Sponsors, Pharmacists, and Beneficiaries in 2008

BACKGROUND: The Medicare Drug Benefit (Part D) was implemented on January 1, 2006. The principal emphasis in the first year was education of beneficiaries as part of the effort by health plans and prescription drug providers to enroll beneficiaries. There was continued emphasis on enrollment in the second year in 2007, with some refinement of the benefit such as removal of coverage for erectile dysfunction drugs. OBJECTIVES: To (1) review policy statements released by the Centers for Medicare and Medicaid Services in 2007 for the Medicare drug benefit, (2) compile an abridged version of the highlights from the policy statements, and (3) describe implications that affect Part D plan sponsors, pharmacists, and beneficiaries in 2008. METHODS: We reviewed more than 200 policy statements, including guidance, memos, announcements, and other communications that were released between January 1, 2007, and September 30, 2007. We selected those policy statements that described substantive changes in the Medicare drug benefit and summarized those that were determined to be most relevant to plan sponsors, pharmacists, and beneficiaries for 2008. RESULTS: Policy statements summarized in this article fall into 12 categories that have the greatest relevance to plan sponsors, pharmacists, and beneficiaries in 2008: (1) the standard drug benefit, (2) redetermination of low-income subsidy (LIS) status, (3) reassignment of some LIS beneficiaries whose plan premium exceeds the 2008 benchmark by more than $1, (4) allowable marketing activities for pharmacists, (5) Medicare Advantage special enrollment period, (6) member transition process, (7) best available evidence for determination of LIS, (8) formulary review process, (9) redefinition of specialty-tier medication from a cost threshold of $500 in 2007 to $600 in 2008, (10) drugs that have a limited distribution network (i.e., specialty pharmacy drugs), (11) formulary reference file, and (12) transfer of reimbursement of the administration fee for Part D vaccines from Medicare Part B to Part D. CONCLUSIONS: The Medicare drug program continues to be refined in 2008, including coverage of the cost of Part D vaccines and their administration fee entirely within Part D. Pharmacists will continue to be an integral part of the success of Medicare Part D in 2008 by being informed of the many changes to the benefit and adapting to these policies and regulations in a way that allows beneficiaries maximum access to the improved features and necessary medications.