Tara Dwyer on Medicare Part D

2017 OIG Work Plan: For Medicare Plans

Last week, the OIG posted its Work Plan for 2017. In it, the OIG announced many goals touching on programs including, but not limited to, Medicare, Medicaid, Insurance Marketplace (Health Exchanges), Indian Health Service,...more

11/16/2016 / Drug Pricing , Medicare , Medicare Advantage , Medicare Part B , Medicare Part D , OIG , Risk Adjustment Formula

2017 MA and Part D Audit Protocols and Data Requests are Open for Comment

CMS issued its Audit Protocols and Data Requests for Medicare Advantage and Part D plans on November 4, 2016 (the “Protocols”). The Protocols have been updated based on the over 500 comments CMS received in response to the...more

11/14/2016 / Centers for Medicare & Medicaid Services (CMS) , Medicare , Medicare Advantage , Medicare Part D

Senate Bill Targets Part D DIR Fees

Just last month the “Improving Transparency and Accuracy in Medicare Part D Spending Act” was introduced in the Senate to amend the Social Security Act. The bill seeks to prohibit Part D plans (and their contracted pharmacy...more

10/12/2016 / Centers for Medicare & Medicaid Services (CMS) , Medicare Part D , Pharmacies , Point of Sale Terminals , Remuneration , Social Security Act , Transparency

OIG Advisory Opinion Approves Drug Discount Program

Last week, the OIG posted favorable advisory opinion (16-07) regarding a proposed discount program for Part D beneficiaries who are prescribed a statutorily excluded erectile dysfunction drug. The OIG concluded that while...more

7/6/2016 / Anti-Kickback Statute , Discounts , Drug Pricing , Medicare Part D , OIG , Pharmaceutical Industry , Rebates

Part D Woes, According to the OIG

On June 23, 2015, the OIG issued two reports focusing on fraud, waste, and abuse in the Part D program, the first “Ensuring the Integrity of Medicare Part D” and the second “Questionable Billing Practices and Geographic...more

7/2/2015 / Centers for Medicare & Medicaid Services (CMS) , Fraud Alerts , Healthcare , Medicare , Medicare Part D , OIG , Prescription Drug Coverage , Prescription Drugs

CMS Changes Medicare Prescriber Enrollment Requirements

On May 6, 2015, CMS issued interim final rules relating to Medicare Part D beneficiary access to Part D drugs. Through the rules, CMS announced updates regarding the impending prescriber enroll or opt-out effective date,...more

5/15/2015 / Centers for Medicare & Medicaid Services (CMS) , Health Care Providers , Healthcare , Medicare , Medicare Part D , Prescription Drugs , Proposed Regulation

CMS Releases 2016 Draft Call Letter

Last week, the Centers for Medicare & Medicaid (CMS) released its 2016 Advance Rate Notice and draft Call Letter (2016 Call Letter) for the Medicare Advantage (MA) and Medicare Part D programs. The 2016 Call Letter outlines...more

2/27/2015 / Centers for Medicare & Medicaid Services (CMS) , Medicare , Medicare Advantage , Medicare Part D , Pharmaceutical Industry , Pharmacies , Physician Medicare Reimbursements

Front End Changes and, Again, More DIR Columns

Since the beginning of the Medicare Part D program, CMS has introduced many reporting mechanisms for trying to understand drug pricing, price concessions, and the cost of providing services to Part D members. The tool CMS...more

10/20/2014 / Centers for Medicare & Medicaid Services (CMS) , Health Plan Sponsors , Healthcare , Hospitals , Medicare Part D , Pharmaceutical Industry , Pharmacies , Prescription Drug Coverage , Prescription Drugs , Reporting Requirements

CMS Continues to Struggle with How to Provide High Quality Care to Dual Eligibles

Last week CMS announced that it would not execute its option to terminate its 2015 contracts with Medicare Advantage Plans and Part D plans that had scored three stars or less for three consecutive years. ...more

9/22/2014 / Centers for Medicare & Medicaid Services (CMS) , Healthcare , Medicare , Medicare Advantage , Medicare Part D

Prescription Drugs: Refocusing the False Claims Act Microscope on the Rest of the Transaction

Over the last decade, it has often felt as though the pharmaceutical industry has been the government’s and whistleblowers’ main, and at times only, target for False Claims Act (“FCA”) investigations. While manufacturers are...more

8/26/2014 / False Claims Act (FCA) , Medicaid , Medicare , Medicare Part D , Pharmaceutical Industry , Pharmacies , Prescription Drugs , Walgreens , Whistleblowers

CMS Proposes Major Changes to Medicare Parts C and D

On January 10, the Centers for Medicare & Medicaid Services (CMS) published proposed rules labeled as “policy and technical” changes to the Medicare Advantage (Part C) and Medicare Prescription Drug Benefit (Part D) Programs....more

1/22/2014 / Centers for Medicare & Medicaid Services (CMS) , Medicare , Medicare Part C , Medicare Part D

CMS Publishes 2014 Final Call Letter

Yesterday, CMS released its 2014 Final Call Letter for the Medicare Advantage and Medicare Part D programs....more

4/2/2013 / Centers for Medicare & Medicaid Services (CMS) , Medicare , Medicare Advantage , Medicare Part D

Tara Dwyer

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