Melissa Newton Smith’s Post

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Government Programs Advisor & Consulting Leader

This weekend #CMS issued a #Medicare Final Rule with new #PartD technical requirements. In addition to regulatory updates, this rule itself is a crucial reminder for #MA plans:  ✅ This FR codifies previous Proposed Rules which remained unfinalized. ✅ This FR reminds plans that unadjudicated #MedicareAdvantage #StarRatings proposals (including increase of #Improvement measure #HoldHarmless from 4 to 5 stars and removal of cutpoint guardrails from non-CAHPS measures) remain alive and can be finalized by CMS without additional rulemaking. From a technical perspective, among other things, this FR:   1️⃣ Requires Part D plans, prescribers and dispensers to to exclusively use NCPDP Formulary & Benefit standard for electronic transmission of formulary/benefits info (including ePA) by 1/1/2027. 2️⃣ Requires RTBTs to comply with RTBT standard v13 (adopted by ONC) by 1/1/2027. 3️⃣ Codifies many technical/technological details to align CMS and #ONC. If you’re not in the pharmacy space, why should you care? Here are 4 reasons: ⚠ This illustrates that pending high-impact #Stars changes can still be codified. ⚠ CMS admits this FR is needed because recently-codified RTBT requirements were created in absence of industry-wide standards, and as ONC catches up to policy needs, new regs will be established despite impact to providers, plans and vendors. ⚠ Last week’s restated Star Ratings to correct #Tukey errors may increase 2025 Medicare spending by up to $1 billion. CMS may seek methods by which to make that change budget neutral, which the proposals to remove guardrails and change the Improvement measure Hold Harmless provisions could achieve. ⚠ January's #Interoperability FR was complex and TL;DR for many, but it will trigger more #HHS Interagency alignment and regulatory adjustments sooner rather than later. Here are a few things insurors, providers and vendors outside of Part D should consider in response to this FR: ✔ How ready are you for January’s Interoperability FR? ✔ What gaps exist between your current status and looming Interoperability requirements? ✔ How might greater CMS/ONC alignment impact your organization? ✔ What strategic investments do you need to consider to ensure your readiness? With #PartDRedesign and the #IRA about to kickstart the most disruptive pharmacy changes since Part D launched in 2006, early adopters of these new requirements will lead the way in #CAHPS and #memberexperience. This is a great time for Stars teams to continue reminding executives that ambiguity and uncertainty is exactly what CMS wants! They want free markets to force us to strive as high as we're willing in order to reap #QBP rewards. Whether you are seeking corporate or personal leadership development and growth, our Reality-Based Improvement Institute has been designed to drive success amidst uncertainty. Reach out if you’d like to learn more. #WhatGotYouHereWontGetYouThere #LetsRoll ⭐ ⭐ ⭐ ⭐ ⭐

2024-12842.pdf

govinfo.gov

Melissa Newton Smith

Government Programs Advisor & Consulting Leader

3w

Ana Handshuh, CHC I think this FR provides the official answer to our "What If" slide from #Qualipalooza2024 earlier this month! Looks like everyone needs to be alert in case those pending Stars proposals are codified in the future....

Amanda Lambert

We can’t drink on the job. We at least need to laugh.

3w

Great information, Melissa! Part D redesign is no joke!

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