Special Health Plan Discussion – Monday, July 1st

Special Health Plan Strategy Discussion

We want to hear from you! | Join the discussion on July 1st, 2024 at 2:00 PM (EDT)

The Roundtable is hosting a special Zoom meeting to discuss the impact of M3P on public sector health plans.

Over the course of the last several months, the Roundtable has been working with our Board and a group of concerned members to educate plans about the impact of the provisions of the M3P on EGWPs and to communicating serious concerns to CMS and others regarding the unintended consequences of this program.

The Roundtable requested an exemption from the ‘co-pay smoothing’ in a comment letter to CMS last September. Despite recognizing the importance of monthly payments for Part D enrollees, the letter argued that EGWP beneficiaries are already protected from high out-of-pocket costs. In addition, we raised concerns about potential confusion for EGWP enrollees with the new payment option, as well as the administrative burden and cost implications for Roundtable members and their contracted EGWPs. To date, CMS has argued they don’t have the authority to grant such a waiver.

At 2:00 PM (EDT) on Monday, July 1st, the Roundtable will host a strategy and educational Zoom meeting for public sector health plans. In addition to Roundtable staff, the discussion will be directed by:

  • Katrina Daniel, Chief Health Care Officer, TRS of Texas
  • Jane Cheshire Gilbert, CPA, Senior Federal Strategies Liaison, TRS of Kentucky
  • Anthony J. (Tony) Roda, Principal, Williams & Jensen
  • Christopher Sears, Senior Counsel, IceMiller

In addition to providing additional education to Roundtable members and friends, our goal is to develop a strategy and message that will inform our ongoing activity with CMS and Members of Congress.

Register for Monday’s Zoom meeting here.

Here is some background for the discussion:

From the comment submission period on the M3P Part One guidance, the Roundtable and others expressed the following concerns:

  • Some suggested waiving or delaying application due to perceived lack of benefit for EGWP enrollees.
  • Concerns about EGWPs lacking reserves for medication out-of-pocket costs and need for discretion in plan management.
  • Worries about increased premiums and reduced enrollment in EGWPs due to M3P.
  • Certain EGWPs, like public trusts, may lack authority to participate due to restrictions on paying private debts.
  • Request for guidance on non-calendar year EGWPs and clarification on program election during Part D enrollment for EGWPs using Group Enrollment Mechanism.

CMS’s response to commenters stated:

  • CMS disagreed with requests to delay or exempt EGWPs from Medicare Prescription Payment Plan.
  • Statutory provisions mandate all Part D enrollees, including EGWPs, be offered participation.
  • Waiving EGWP requirements could deprive beneficiaries of potential benefits.
  • EGWPs have ample time to arrange finances for program administration before 2025 plan year.
  • CMS clarified it cannot waive requirements for EGWPs to maintain full discretion over plan design.
  • CMS stated: “After consultation with the IRS, CMS does not believe that the Internal Revenue Code prohibits EGWPs from complying with the requirements of the Medicare Prescription Payment Plan and providing their enrollees with the option to participate.”
  • Guidance for non-calendar year EGWPs and program election process directed to Draft CY 2025 Part D Redesign Program Instructions.

Roundtable’s 20th Annual Conference

November 6-8, 2024

The Mayflower Hotel, Washington, DC