CMS Issues a Set of Frequently Asked Questions Related to the Medicare Prescription Payment Plan

On Oct. 1, 2024, the Centers for Medicare & Medicaid Services (CMS) issued a set of frequently asked questions (FAQs) related to the Medicare Prescription Payment Plan. The FAQs include the following clarifications:

• Charitable assistance or supplemental coverage for covered Part D drugs should be processed before submitting the final transaction to the program-specific BIN/PCN. Part D sponsors should continue to process claims in the established payer order discussed in the Medicare Prescription Drug Benefit Manual, Chapter 14, Section 30.3.
• If a Part D enrollee participating in the Medicare Prescription Payment Plan makes a mid-year plan switch to a different plan benefit package (PBP) offered by the same Part D sponsor, the sponsor cannot automatically keep the enrollee’s election active. However, the enrollee may elect into the program for their new Part D plan.
• If an individual’s request to participate in the Medicare Prescription Payment Plan is denied, the Part D sponsor is responsible for notifying the individual and explaining the reason for the denial. A request may be denied if:
  • The individual is not a member of the Part D plan,
  • They fail to timely submit requested information, or
  • They switch to a new plan from the same Part D sponsor but have a past due balance with their prior plan.
• Part D enrollees can opt into the Medicare Prescription Payment Plan prior to the plan year during the Annual Election Period or between the Annual Election Period and the beginning of the plan year. The request must be processed within the shorter of 10 calendar days of receipt or the number of calendar days before the plan enrollment starts.
• CMS encourages Part D sponsors to refer to the Medicare Prescription Payment Plan in their outreach and educational materials using this full name, “Medicare Prescription Payment Plan,” rather than an abbreviation such as “M3P,” “MPPP,” or “MP3.”
• For election requests received during the plan year, the Part D sponsor must deliver the notice of acceptance within the specified timeframe first by telephone and then via written notice within three calendar days. The initial notice may be completed in real time on the same phone call as the initial election or through digital confirmation for electronic requests.

More on This Topic:

• FAQs Sheet
• Final Part One Guidance
• Final Part Two Guidance
• Medicare Prescription Drug Benefit Manual, Chapter 14

For questions, please reach out to Vicky Jucelin.