Medicare Part D 07/27/2005

    

The Health Care Compliance Association, in an effort to meet your information needs, is asking the following series of questions about the new Medicare Part D’s impact on your organization. Please take a moment to respond to the questions below:

    
1. Is your organization a

Health Plan


10
12%
Health System
16 20%
Hospital
15 18%
Physician Practice
8 10%
Integrated Delivery System
1 1%
Laboratory
2 2%
Long Term Care Facility
5 6%
Hospice or Home Health Agency
0 0%
DME
0 0%
 
Other, Please Specify
25 30%
  82 100%

    
2. Have you attended any training related to the Medicare Part D regulation?

Yes


33
40%
No
49 60%
  82 100%

    
3. Have you examined/assessed the compliance implications of Part D on your organization?

Yes


36
44%
No
45 56%
  81 100%

    
4. Will the new Medicare Part D Regulation impact your organization?

Yes


51
67%
No
25 33%
  76 100%

    

5. If you answered “Yes”, what aspects of Part D will affect your organization? (Please list)
Respondent Number Response
1 actually I'm not sure its no - but I think that's the case.
2 1. Notice to CMS about Creditable Coverage. 2. Notice to subscribers about creditable coverage. 3. Coordination of Benefits Agreement. 4. Internal training of customer service/sales staff.
3 We are a medicaid program and we have dual eligibles who will be impacted
4 Pharmacy benefits and treatment for Medi-Medi mental health clients
5 We are required by state law to assist our clients with all entitlements for which they may be eligible. Thus our staff will have to understand and be able to assist clients with applications, etc.
6 Reimbursement of Medications for Medicare primary and secondary.
7 Plan benefits, contracting, compliance, customer service
8 Outpatient pharmacy, formularies, claims
9 Outpatient Infusion Center Drug Reimbursement. Outpatient Pharmacy reimbursement
10 outpatient pharmacy
11 Many consumers in our ARC system are dually enrolled/medicaid and medicare. Many of same consumers are patients at our Outpatient health center. medically frail population served with many medications, and formulary issues will arise
12 Collection of co-pays Whether or not to treat one population different from others Affect on us as a Safety Net Hospital
13 Clinics will need to screen patients for Part D eligibility. Loss of revenue as dual-eligibles transition from Medi-Cal (Medicaid) to Part D. More ill patients when they exhaust Part D Benefits and have insufficient funds to pay for medications. Increase of costs to Indian organizations for those patients for whom the organization pays for outside services. Concomittent reduction of the number of outside services for which the organization pays as the pharmacy costs escalate. Confusion for patients who may be signed up for a plan in which the clinic is not a pharmacy provider. Clinics have to apply to multiple plans (one Indian clinic in CA currently is signed up with 12 plans).
14 we will now cover drugs for our Duals.
15 The training mission for staff and recipients will be extensive and complex.
16 financially
17 Don't Know
18 reimbursement for in-office pharmaceuticals and the way we purchase them
19 1. We will be offering a Part D plan, so all the issues related to selling and administering a product will apply.
20 Over laps with medicaid members
21 Sales operations contracts/ managed care marketing/ Training of representatives/ Co-marketing partnerships
22 We have applied to be a MAPD
23 SNF patient care& billing. Assisted Living patient care. Medicaid program stability
24 MMA
25 LTC issues around benficiary choice of PDP creates problems. We are working with our institutional pharmacy to develop plans. Training is occurring and being provided by our pharmacy group.
26 our Residential services consumers will need assistance in evaluation the best option for them, and many (about 65%) are dually enrolled in Medicaid and Medicare
27 Operations
28 This is still up in the air as Pennsylvania is attempting to opt out of the new program in lieu of our current PACE program. If CMS does not allow PA to opt out, there will be changes in the way that drugs are paid for and what drugs are actually covered.
29 Large part of population disabled and are impacted
30 Patient's ability to purchase prescriptions and office stock of injectables.
31 We will continue to offer prescription coverage to our retirees, and our coverage has been actuarially determined to be equivalent or better than Medicare Part D. Therefore, we will participate in the subsidy program. We have our notice and COCs ready for distribution.
32 Pharmacy Medical Management Grievance & Appeals IT Enrollment Marketing Compliance
33 We have patients who qualify for Medicare Part D.
34 But not sure the scope or depth
35 legal relationships between and among Part D Plans, Medicare Advantage Plans, Hospitals, retail, inpatient and institutional pharmacies and nursing facilities
36 outpatient services
37 Part D prescription benefit
38 Reimbursement for drugs use in outpatient infusions, etc.
39 MA-PD implementaion touches nearly every departmetn Fraud & Abuse Contracting Compliance training and education COB
40 Outpatient Pharmacy Services
41 Coverage for self-administered medications.
42 PHARMACY
43 Dual Eligiblity
44 Increased reimbursement as we are IHS

    
6. Will your compliance training and education program include information about Part D

Yes


27
38%
No
45 63%
  72 100%

    

7. If your organization has affiliations and/or contracts with provider groups, what steps have you taken to prepare for Medicare Part D (January 2006)? Please list
Respondent Number Response
1 Internal discussions Discussion with local Medicare Advantage provider
2 review of proposed formularies, meetings with pharmacy management
3 None, yet
4 We have none.
5 None that I am aware of.
6 in-service meeting
7 Our organization would be more involved with the recipients of Part D.
8 none
9 general information preparing inservices
10 Meetings/ discussions
11 N/A - We will probably just print the CMS material and make it available to patients at Registration if they have questions.
12 using state organization to share participation work
13 Education, training and update maintenance on regs.
14 N/A
15 We are NOT affiliated with any provider groups.
16 We have set up 2 seminars with an outside consultant coming in to speak to providers and staff about Medicare Part D.
17 We have had our actuary compare our coverage to that of Medicare Part D. We have our notice and our COCs ready to distribute, and we are working on any possible COB issues that may arise.
18 Once CMS approves the benefit plans that were submitted in June 2005, we will conduct training programs for providers regarding the new enrollment period (i.e.lock-in) and benefit designs.
19 Initiated training. Developed workplan. Receiving training from SSA and CMS.
20 CMS listserve and "open door" audioconference participation
21 contract amendments
22 New Contracts Training for Billers
23 None at this time.

    
8. Is your organization affiliated with pharmacy services?

Yes


34
44%
No
43 56%
  77 100%

    

9. If you answered “Yes” to the question 8, please list the steps you have taken to insure you have an understanding of Medicare Part D and its effect on your organization”
Respondent Number Response
1 Only minimally, radioisotopes
2 Internal discussions discussions with local medicare advantage provider
3 Legal/Compliance review of applicability
4 reading, attended a CMS seminar
5 Have not taken any steps to this point
6 Pharmacy Services support inpatients only.
7 Just beginning to analyze the impact
8 pharmacy services is a for profit affiliate of the system. They are assessing the program internally.
9 Pharmacy has taken on that role without much input from the Compliance Dept
10 Our pharmacy services coordinator has conference calls with the pharmacists at member programs. He distributes information about Part D as it becomes available; evaluates regulations; provides review of contracts as necessary. Our Executive Director sits on a Technical Advisory Group to CMS, to evaluate impact in Indian country and make recommendations to CMS. He provides information to clinic Executive Directors on potential policy issues and impacts on Indian health clinics.
11 inservice training
12 as much training has been available
13 But not on a take home basis
14 Health plan is leading preparation
15 same
16 See answer to questions 5 and 7 above.
17 We have implemented a Medicare 2006 Implementation team that is comprised of all the areas impacted by Part D.
18 We provide prescriptions (bulk and PAP). We are working to ensure patients, providers and support staff understand the regulations
19 Attended workshops and reviewed issues briefs from NACDS
20 hired a consultant working collaboratively with PBM
21 Nothing yet
22 Reviewed potential coverage information to prepare for additional Part D plan billing.
23 Leadership training and specific staff training by outside consultant
24 Business Office staff have been educated

    
10. Would you be interested in HCCA providing information/training on Medicare Part D

Yes


45
56%
No
35 44%
  80 100%

    

11. If you answered “Yes”, please list the issues or topics related to Medicare Part D which you would like to see addressed either in articles or at a conference (please list)
Respondent Number Response
1 with reference to outpatient pharmacy, retail pharmacy, effect on physicians
2 How do we decide whether to continue to provide current services under the new reimbursement scheme.
3 What else does PArt D cover? I thoght it covered preventitive services such as mammograms....
4 Collection of co-pays vs. provision of non-urgent care
5 Information that hospitals can share with patients/beneficiaries on the program.
6 Compliance issues for Part D; monitoring of same; enforcement
7 A very brief and general overview of the Part D coverages and policies.
8 This is not my area and I do not have the authority to commit state funds. Training of this nature is arranged by another unit.
9 any and all
10 In relation with Medicaid
11 Dual-eligibles, patient assistance programs, how will patient 'donut hole' expenditures be tracked to assure proper accounting, especially if they use multiple and/or independent pharmacies for fulfillments ?
12 Compliance monitoring for Part D Risk areas
13 Applicable compliance risk areas.
14 Subsidy issues; Coordination of benefits issues; Communication issues
15 Grievance, Appeals, Exceptions process Rules for changes to the formulary COB guidance for MA-PD's CCIP Program requirements, including reporting requirements
16 It is too late. Updates later as changes occur.
17 General provisions; most likely impacts on health systems; where is greatest risk or exposure; what can we do to prepare our hospitals to assess and deal with the risks
18 How Part D affects hospital-based pharmacies that are not retail facilities.
19 False Claims Act implications of NDC numbers and drugs not on plan formulary not being covered by Part D. (full disclosure: this is the topic that I am proposing to HCCA for its upcoming seminar)
20 overview impact on compliance
21 Model program for Compliance with part D: Sample policies, audits, training materials for pharmacists, etc
22 COB Fraud and Abuse
23 Coverage issues for billing compliance.
24 RX
25 Dual Eligibility Reimbursement