In March 2005, the Centers for Medicare & Medicaid Services (CMS) issued a guidance that all Part D plans must have a transition plan to allow for an appropriate amount of time for a plan or beneficiary to contact the provider for any necessary therapeutic changes to formulary medications. (see Medicare Byte: Part D Formularies). This transition policy was intended to give Medicare patients at least a 30-day grace period to continue taking non-formulary medications at the start of the Medicare Part D program.
Now, Medicare has notified Part D plans that the 30-day transitional coverage period must continue for 60 more days. This allows extra time for plans, patients, and pharmacists to work with providers to move to formulary medications while still receiving coverage for non-formulary medications.
Where to access formulary information. Part D plans are required to
disclose formulary information on their Web sites. For an easy reference,
pharmacists can access PDP formulary information at www2.epocrates.com/index.html. It provides both tier and step
therapy information, is updated constantly, and can easily accessed by computer
or downloaded to a PDA. When changes are made to Part D formularies, plans are
required to notify pharmacists, prescribers, and patients 60 days in
advance.
Formularies too restrictive? Remember, dual eligibles can change
plans every 30 days. For 2006, all Medicare patients can change plans once prior
to May 15. This is an excellent opportunity to work with patients to move
to a plan with a more appropriate formulary for them. However, advise your
patients to change by the 15th of the month to allow ample time for the
enrollment to be processed by the plan and verified by
Medicare.
Caution with transition prior authorization codes. While the creation of one transition prior authorization code is helpful to save time at the pharmacy counter, it may provide headaches in the event of an audit. Be careful to not use transition prior authorization codes after March 31 unless directed by a Part D plan.