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No Call Letter + COVID-19 = Confusion for Medicare Contract Year 2021: Clarifying What You Need to Know

May 21, 2020

In the past, the Centers for Medicare and Medicaid Services’ (CMS’) process was to provide the proposed guidance and methodology for the upcoming contract year (CY) through the Advance Notice and Call Letter. However, this year, CMS divided the Advanced Notice into two parts, released the Proposed Rule (CMS-4190-P) and issued multiple HPMS Memo notifications. That means to obtain an overall picture of the CY 2021 regulatory guidance landscape, plan sponsors and stakeholders need to review all the items listed below:

CMS Guidance Release Date Comments Due Final Release Date
CY 2021 Advance Notice Part I January 6, 2020 March 6, 2020 April 6, 2020
CY 2021 Advance Notice Part II February 5, 2020 March 6, 2020 April 6, 2020
CY 2021 and 2022 Medicare Advantage and Part D Proposed Rule (CMS-4190-P) February 5, 2020 April 6, 2020 TBD - Delays due to COVID-19
CY 2021 Part C Benefits Review and Evaluation Via HPMS Memo March 9, 2020 TBD - Delays due to COVID-19
CY 2021 Final Part D Bidding Instructions Via HPMS Memo N/A N/A
CY 2021 Medicare Parts C and D Annual Calendar Via HPMS Memo N/A N/A

With the COVID-19 crisis, stakeholders have been reaching out to CMS asking for flexibility on the implementation of some of the proposed rule timelines. All of this adds up to some health plans feeling confused. While only time will tell if CMS will make certain proposed rule changes voluntary in light of COVID-19, the EnvisionRx Compliance team has reviewed all of the guidance and calculated how the proposed changes impact Part D plans.

The Solution: Proposed Rule (CMS-4190-P) Part D Enhancements for CY 2021

Real Time Benefit Tool (RTBT) - The proposed rule would require Part D plans to offer real-time drug price comparison tools to beneficiaries starting January 1, 2022. With an RTBT, enrollees can review the options under their prescription drug benefit plan and choose lower-cost alternative therapies. To encourage enrollees to use the RTBT, CMS is proposing allowing plans to offer rewards and incentives to their enrollees who log on to the RTBT or seek to access this information via the plan’s customer service call center. 

Second “Preferred” Specialty Tier – Beginning January 1, 2021, the proposed rule will allow Part D sponsors to establish a second “preferred” specialty tier with a lower cost sharing amount than the current specialty tier. This proposal is designed to give Part D sponsors additional tools to lower out-of-pocket costs for enrollees. Plan sponsors would be able to request a better deal from manufacturers of the highest cost drugs in exchange for placing their products on the “preferred” specialty tier.

SUPPORT Act - The proposed rule would implement several provisions of the Substance Use-Disorder Prevention that Promotes Opioid Recovery and Treatment (SUPPORT) for Patients and Communities Act. These provisions require Part D plans to educate beneficiaries on opioid risks, alternate pain treatments and the safe disposal of opioids.

Mandatory Drug Management Programs - The proposed rule also expands drug management programs and medication therapy management programs where Part D plans work with providers to review opioid utilization trends that may put beneficiaries at risk and provide beneficiary interventions. CMS hopes these provisions will prevent and treat opioid overuse.

Get More Direction on the Proposed Rule Requirements

Learn more during our free Compliance Roundtable webinar, Navigating the 2021 Rate Announcement and Proposed Rule Requirements, Wednesday, June 3, 2020 from 2-3 p.m. ET. During the informative webinar, BluePeak Advisors’ Medicare experts will provide details to help you navigate the proposed changes. Click here to register.

Centers for Medicare & Medicaid Services. (2020). Contract Year 2021 and 2022 Medicare Advantage and Part D Proposed Rule (CMS-4190-P). Newsroom. Retrieved from

Centers for Medicare & Medicaid Services. (2020). Proposed Changes to Medicare Advantage and Part D Will Provide Better Coverage, More Access and Improved Transparency for Medicare Beneficiaries. Newsroom. Retrieved from

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