Radar on Medicare Advantage

For the first time ever, Medicare Part D beneficiaries in 2025 will have the opportunity to spread their prescription drug expenses over the course of the plan year. While Part D sponsors must offer the option to enrollees effective Jan. 1, 2025, plans face multiple considerations and tasks prior to then. One of their most immediate concerns, industry experts say, is factoring in potential administrative costs and/or financial losses associated with the new Medicare Prescription Payment Plan (M3P, as many are calling it) into bids due next month.

Created under the Inflation Reduction Act, the M3P requires stand-alone Prescription Drug Plans and Medicare Advantage Prescription Drug plans to give enrollees the option to pay out-of-pocket prescription drug costs in the form of capped monthly payments versus paying the full amount at the pharmacy. Program participants will pay $0 at the pharmacy but receive a monthly bill from their Part D carrier, which must reimburse the pharmacies in full.

As Medicare Part D sponsors consider critical steps to setting up the new Medicare Prescription Payment Plan (M3P), CMS is weighing feedback from stakeholders on various aspects of the program, from beneficiary communications to pharmacy interactions. And some warned that potential beneficiary confusion may lead to increased complaints that impact plans’ Star Ratings.

The M3P, which takes effect on Jan. 1, 2025, requires both stand-alone Prescription Drug Plan and Medicare Advantage Prescription Drug carriers to give beneficiaries the option to spread their pharmacy costs over the plan year via a capped monthly payment. CMS in February issued its second draft guidance on the M3P and asked for comments no later than March 16. CMS plans to release the final guidance this summer. The agency sought comment on model materials issued through an Information Collection Request (ICR), including a standardized notice that plans would be required to use for targeted outreach to enrollees who are likely to benefit from the M3P. The initial 60-day comment period on the model materials ended April 29; CMS said it expects to issue a second, 30-day comment period in Spring 2024.

In recent years, publicly traded managed care organizations have jumped on a growing corporate trend of publishing annual environmental, social and governance (ESG) reports designed to spotlight the larger impact their company is having on society. Alignment Healthcare Inc., for one, in 2022 released its inaugural ESG report highlighting efforts from the previous year that focused on delivering high-quality care at a lower cost compared to fee-for-service Medicare and addressing social determinants of health (SDOH). In 2023, The Cigna Group’s 98-page ESG report categorized similar efforts into four “pillars” — healthy society, healthy workforce, healthy company and healthy environment — and included efforts to reduce greenhouse gas emissions in the latter category.

In a 2022 podcast hosted by law firm K&L Gates LLP, speakers suggested that the health care industry by nature is “mission-driven…focused on the improvement of the human condition” and “is particularly well suited to address ESG issues.” And insurers’ efforts in recent years to address health inequities mirror the increased focus from the Biden administration and CMS on tying health equity to reimbursement, such as the CMS Innovation Center incorporating health equity into models that drive value-based care.