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Stephanie Pellitt

, National Council for Behavioral Health

CMS Releases 2020 Medicare Advantage and Part D Draft Call Letter

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On Thursday, the Centers for Medicare and Medicaid Services (CMS) released its Medicare Advantage (MA) and Part D draft call letter for 2020, which outlines changes to Medicare plan policies and payments each year. The call letter lays out several proposals for combating the opioid crisis that would encourage plans, among other things, to make naloxone and non-opioid pain treatments more accessible. Additionally, CMS proposes to give Medicare Advantage plans more flexibility to offer supplemental benefits to chronically ill beneficiaries and to require Part D plans to place generic and brand-name drugs on separate formulary tiers.

The major provisions of the draft call letter are described below:

  • Addressing the Opioid Crisis: The draft call letter for calendar year (CY) 2020 proposes improvements intended to help address the opioid epidemic through MA and Part D. This includes implementing provisions of the SUPPORT Act that require the coverage of opioid treatment programs, including medication-assisted treatment (MAT).Additionally, CMS is encouraging plans to lower cost-sharing for naloxone and to co-prescribe naloxone alongside high-dose opioid prescriptions. Furthermore, CMS reminds MA organizations that supplemental benefits may cover non-opioid pain management, such as peer support services, cognitive behavioral therapy and therapeutic massage if advised by a doctor.CMS also indicates that it will increase surveillance of opioid misuse with its overutilization monitoring system.
  • Supplemental Benefits: Following its rule change to allow certain supplemental benefits that are not “primarily health related,” CMS is proposing in the draft call letter to allow MA plans to offer non-primarily health related supplemental benefits to chronically-ill enrollees, which can include non-medical transportation and meal delivery.
  • Generic and Brand Formulary Tiers: In an attempt to reduce beneficiaries’ out-of-pocket costs and “reduce confusion,” CMS is considering prohibiting Part D plan formulary tiers from including both generic and brand products, seeking instead to keep generics and brands on separate tiers. It also seeks comment on whether biosimilars should be treated the same as generics for this purpose.
  • Star Ratings Changes: CMS is proposing that opioid use measures be included in the star ratings for Medicare Advantage plans. These measures would be capable of tracking the use of high-dosage opioids from multiple providers and flagging concurrent use of opioids and benzodiazepines.

Additionally, CMS proposes to adjust CY 2020 star ratings for MA and Part D plans to account for “extreme and uncontrollable circumstances.”

CMS is soliciting comments on the Advance Notice and Draft Call Letter, which are due to the agency by March 1, 2019. CMS anticipates publishing the final 2020 Rate Announcement and Call Letter on April 1, 2019. See the following press release and fact sheet for more information about the draft call letter.