Debra Devereaux

Good to Know

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Usually CMS leaves us wondering about the benchmark that they have in mind for plans to achieve.  But the latest 2013 Draft Call Letter left little to the imagination. 

It states, “We expected more Part D beneficiaries would be eligible for MTM following changes to the eligibility criteria requirements in 2010. However, the eligibility rate has remained at 10 to 13% since 2006. We are concerned that the Part D sponsors are restricting their MTM eligibility criteria to limit the number and percent of beneficiaries who qualify for these programs and are required to be offered CMRs.”

By reading the tea leaves, one can surmise that CMS thinks a ten to thirteen percent (10%-13%) MTM eligibility rate is not high enough. CMS is further adding the percentage of Comprehensive Medication Reviews as a Part D star measure and adding Alzheimer’s and End Stage Renal Disease with dialysis as chronic conditions. There is a required MTM format now and increased emphasis on increased contact with members to get them to agree to a Comprehensive Medication Review.

When considering Medication Therapy Management program criteria to be submitted (due May 7, 2012), organizations should consider expanding the program criteria so that more members are eligible and requiring their MTM vendor or their internal staff providers to get the Comprehensive Medication Review numbers way up.  This time CMS has given us a good look at where the bar is.

Debra Devereaux

About Debra Devereaux

Debra Devereaux brings to Gorman Health Group clients eight years of Medicare Part D operations expertise. Since the inception of Medicare Part D she has led a number of engagements for GHG, including interim Director of Pharmacy, development of applications for new MA-PDs and SNPs, CMS corrective action plan responses, mock audits and audit preparedness, PBM contracting and implementation, Part D compliance, Medication Therapy Management auditing and strategy, and Delegation Oversight and Monitoring. Deb leads a team of pharmacists and business analyst consultants with broad health plan, CMS and PBM experience.

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