OPA's Comments on New Medicare Card GuidelinesCo-branding
We support the provisions prohibiting the displaying provider or providers co-branding names and/or logos on the organization's member identification card. However, the prohibition should be expanded to include non-provider entities names and/or logos. Separate non-provider entities may have affiliations with participating providers that would provide the same confusion that currently exists under today's environment. We urge that co-branding symbols on cards be limited only to qualified State Pharmaceutical Assistance Programs and any other instance be clearly prohibited.
Benefit Changes in Marketing Materials
The recommended statement that plans may use if they anticipate a change in the benefit in the upcoming year should only be used if specific changes are not know at time the materials are being developed. Any specific change known should be clearly identified for the enrollee.
If the Part D plan uses the name and /or picture of a pharmacist and/or pharmacy to market the Part D pan, information should clearly be stated where a complete list of network pharmacies may be found. In addition, plans should be required to explain that both preferred and non-preferred pharmacies are network pharmacies.
Items that might have the effect of inducing enrollees to use particular providers, practitioners, or suppliers should be prohibited.
Availability of Medicare Subsidy Information
We support the provisions requiring inclusion of information regarding extra help that may be available.
Specific Guidance for Medication Therapy Management Programs (MTMPs)
Plans should be required to include information regarding their MTMPs in their marketing materials. MTMPs are a requirement for qualified beneficiaries - plans should be required to identify their criteria for their MTMPs and method to access this benefit.
Pharmacy Directories/Required Pharmacy Information
Plans should be required to include all information on participating pharmacies instead of just for non-chain pharmacies. Not all pharmacies within a given chain may be participating in the given plan or operating under the same name. The burden should not be placed on the chain to have a toll-free number or answer questions regarding specific locationsí participation status in a particular plan. In addition, plans should be required to (rather than may) list both preferred and non-preferred pharmacies in their pharmacy directories. In addition, rather than restrictions imposed on members that use non-preferred pharmacies, the guidance should state "any additional cost sharing imposed..".
Internet Must Use Chart
Plans should be required to include information on MTMPs and MTMPs provider network on their plan website.
Additional Materials Enclosed with Required Post Enrollment Materials
Additional materials that might have the effect of inducing enrollees to use particular providers, practitioners, or suppliers should be prohibited.
Materials Not Subject to Review
General health promotion is not a requirement and we support their materials not being subject to review. However, in the for example, MTMPs materials are included. MTMPs are a required component of this benefit and, as such, materials related to MTMPs should be subject to review. Mail order pharmacy election forms should also be subject to review as plans. Beneficiaries are entitled use the pharmacy of their choice and, as such, any materials that would be provided to beneficiaries regarding their choice of providers should be reviewed.
Specific Guidance about Value-Added Items and Services (VAIS)
VAIS that might have the effect of inducing enrollees to use particular providers, practitioners, or suppliers should be prohibited.
PharmacyTechnical Help Call Center
We applaud the additional guidance provided to organizations regarding their hours of operation, information provided and operating standards. However, we would also urge the pharmacy technical help center to be instructed to be able to provide accurate transition assistance to pharmacy providers.
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October 15, 2015
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