Updated Guidance for Medicare Advantage and Part D Plans Increases Access to Care

Last month, the Medicare Rights Center highlighted guidance that the Centers for Medicare & Medicaid Services (CMS) released for Medicare Advantage (MA) plans, Part D plans, and certain Medicare-Medicaid plans. This guidance described both the options and requirements such plans have for providing Medicare coverage for COVID-19 (also called coronavirus) testing, treatments, and prevention. This week, CMS amended the guidance to reflect additional information and flexibilities. Some of these changes are a result of legislation, while others are decisions made by the agency.

One update, as a result of the Families First Coronavirus Response Act, forbids MA plans from charging any cost-sharing, including deductibles, copays, or coinsurance, for coronavirus tests. This includes the administration of the test and any testing-related services, as well as any future vaccine. In addition, plans may not impose any prior authorization or other utilization management requirements on such testing.

Another change, this time as a result of the Coronavirus Aid, Relief, and Economic Security (CARES) Act, is a requirement that all MA and Part D plans allow 90-day fills of covered drugs during the emergency period if requested by the enrollee. In addition, plans cannot impose quantity limits that would prevent someone from getting a full 90-day supply if they have a prescription for that amount. Certain safety provisions called “safety edits” are still in place to prevent unsafe doses of opioids.

CMS is also encouraging plans to waive requirements for pharmacist consultation with the prescriber, and the agency will not enforce medication delivery documentation and signature requirements. The guidance clarifies that plans may otherwise continue to impose cost and utilization management requirements.

Further, CMS is allowing insurers to make mid-year changes to their plans that would uniformly provide enrollees with additional benefits or more generous cost-sharing. The agency notes that such changes should be tied to the public health emergency. For example, plans could add meal delivery or medical transportation services that support social distancing or reduce or eliminate cost-sharing for telehealth services.

CMS is also giving plans more discretion around disenrollments. CMS is encouraging plans to maintain enrollment for people who fail to pay premiums or no longer qualify for a type of specialized MA plan called a “Special Needs Plan.” In addition, the agency is permitting plans to keep people enrolled if they are absent from the plan’s service area for more than six months due to the pandemic. At Medicare Rights, we support efforts to ensure that people with Medicare have access to the medications and providers they need to maintain their health, financial stability, and well-being during this public health emergency and beyond. We encourage CMS to do more to ensure that everyone who is eligible for Medicare is able to enroll without delay, and we support additional legislative changes that would improve enrollment and appeals processes.

Read the updated guidance.

Read our post about the original guidance.

Read our recommendations for further action.