Concerns Raised Over CMS 2015 Part D Call Letter

In letter to CMS Administrator, HLC President Says Call Letter Provisions Could Lead to “Disruption of Care for Millions of Part D Beneficiaries” 

WASHINGTON — In a letter to Centers for Medicare and Medicaid Services administrator Marilyn Tavenner, the Healthcare Leadership Council (HLC) has raised concerns over the agency’s 2015 Medicare Part D Call Letter, saying that some of the proposals contained within the letter could have the same impact as controversial regulations affecting the drug benefit program that CMS said last month it would not pursue this year.

In the letter, HLC president Mary R. Grealy wrote, “In reviewing the 2015 Part D Call Letter, we note that some of its proposals could have the same effect as parts of the original proposed rule, leading to disruption of care for millions of Part D beneficiaries.”  Ms. Grealy wrote that HLC assumes that “any provisions in the proposed rule which you have indicated you will not finalize this year will also not be finalized in the Part D Call Letter.”

She cited, as examples, that “the Call Letter imposes considerable restrictions on enhanced plans, which we believe will reduce their stability and affordability.  Requiring enhanced alternative plans to cover all formulary generics and all formulary brand drugs (if they cover even a single brand drug) in the coverage gap is not necessary and could result in fewer options, instead of your stated goal of increasing coverage options.”

Ms. Grealy wrote that the agency must take care to avoid reducing Part D program affordability and stability as well as the program’s high level of beneficiary satisfaction, which has been measured at 90 percent in fall 2013 polling by KRC Research.