PAN Foundation submits comments on proposed rule to revise Medicare Advantage Part D program
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The Patient Access Network (PAN) Foundation submitted comments to the Centers for Medicare and Medicaid Services (CMS) on the proposed rule to revise the Medicare Advantage Program, Part D Prescription Drug Benefit Program. PAN has long advocated for a program such as the newly implemented Medicare Prescription Payment Program for Part D enrollees. Because the Medicare Prescription Payment Plan (MPPP) is voluntary and beneficiaries must re-enroll each year, it is critical that CMS implement robust outreach and education efforts to ensure patients are aware of the program–particularly Part D enrollees with high prescription drug costs and limited or fixed incomes.
PAN’s recommendations to CMS on strengthening the Medicare Prescription Payment Program include:
- Codifying program requirements for 2026 and beyond. Codifying the requirements would provide an annual opportunity to review the program’s performance and revise the requirements as lessons are learned during the implementation phase of the program and beyond.
- Modifying the grace period. PAN supports CMS’s proposal to change the date on which the grace period must begin to the first day of the month following the date on which the initial notice is sent.
- Automatic election renewal process. PAN strongly supports CMS’s proposal of an automatic election renewal process that extends a Part D enrollee’s participation in MPPP program for the next calendar year, unless the enrollee opts out.
- Real-time enrollment via phone or web. PAN urges CMS to make point-of-sale (POS) enrollment possible at the pharmacy counter, in addition to self-service web and phone enrollment.
- Additional enhancements to MPPP. PAN supports additional improvements including strengthening requirements around beneficiary communication, enrollment methods and automatic enrollment, more regular reporting on MPPP participation data, and transparent reporting on prescription drug event data.
PAN’s recommendations to CMS also include codifying the requirements related to $0 cost-sharing for adult vaccines, and requiring Medicare Advantage organizations to make provider directory data available to CMS to better populate the Medicare Plan Finder tool.