ARTICLE
14 February 2019

Part D Payment Modernization Model Aimed At Reducing Medicare's Catastrophic Phase Spending

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Mintz is a general practice, full-service Am Law 100 law firm with more than 600 attorneys. We are headquartered in Boston and have additional US offices in Los Angeles, Miami, New York City, San Diego, San Francisco, and Washington, DC, as well as an office in Toronto, Canada.
On January 18, 2019, CMS announced the Medicare Part D Payment Modernization Model, aimed at incentivizing Part D sponsors to reduce catastrophic phase federal reinsurance subsidy spending
United States Food, Drugs, Healthcare, Life Sciences
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On January 18, 2019, CMS announced the Medicare Part D Payment Modernization Model, aimed at incentivizing Part D sponsors to reduce catastrophic phase federal reinsurance subsidy spending.  The model, which will begin January 2020, is a voluntary, five-year model open to eligible standalone Prescription Drug Plans (PDPs) and Medicare Advantage-Prescription Drug Plans (MA-PDs) that are approved to participate.  If a Part D sponsor chooses to apply with a standalone PDP in a Part D region, it must include all of its standalone PDPs in that Part D Region.  Similarly, if a MAO choose to apply with an MA-PD, it must include all of its MA-PD plan benefit packages offered in that Part D region(s).

Under the model, CMS will create a two-sided risk model to incentive PDPs and MA-PDs to lower their catastrophic phase federal reinsurance subsidy spending.  After each plan year, CMS will retrospectively create a spending target for the federal reinsurance subsidy CMS projects would have been paid to a model participants if it was not participating in the model.  Model participants will receive performance-based payments if they stay below their target, but must repay ten percent of the additional spending if they exceed their target.  CMS has not specified how the performance-based payments will be calculated.

In addition, CMS will allow model participants to create Part D Rewards and Incentive programs to strengthen enrollees' clinical relationship with their providers and chosen Part D plans.  CMS indicated that additional programmatic flexibilities will be provided to model participants.

CMS will be releasing a Request for Applications for plan year 2020, and applications will be accepted until March 1, 2019.

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