Maximizing the Medicare Drug Discount Card Subsidy

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• Maximizing the Medicare Drug Discount Card
  Subsidy
• and Part-D State Implementation Status Update
  Web-conference
• December 16, 2004 330 500 pm EST
• 330 335 Dr. Mark McClellan Welcome
• 335 350 Tim Trysla Moderator, Agenda,
  Discount Card
• 350 405 Kim Fox State experience with Drug
  Card Enrollment
• 405-420 Michael McMullan CMS Timeline
• 420 435 Gale Arden Low Income Subsidy
• 435 450 Donna Boswell SPATC Preliminary
  Recommendations
• 450 500 Any Additional Questions/ Wrap Up

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Dr. Mark McClellan

• Welcome

3
Tim Trysla

• Agenda
• Discount Card

4
Kim Fox

• State experience with Drug Card Enrollment

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Maximizing Enrollment in Transitional Assistance
Lessons from Medicare Discount Cards and Other
Low-Income Enrollment Initiatives

• Presentation to the National Governors
  Association
• Kimberley Fox, Senior Policy Analyst
• Rutgers Center for State Health Policy
• December 16, 2004

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Acknowledgement

• Presentation based on
• Study of state pharmacy assistance programs
  funded by The Commonwealth Fund
• Telephone interviews in Spring 2004 with 17
  states re Medicare coordination of benefit
  issues and discount card experience.
• Website with more detailed reports
  http//www.cshp.rutgers.edu/
• Findings from the State Solutions project funded
  by the Robert Wood Johnson Foundation to maximize
  enrollment in Medicare Savings Programs
  (QMB/SLMB/QI1s).

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Estimated Percent of SPAP Enrollees Eligible for
600 Credit

Source Fox, K, Crystal, S. Coordinating Medicare
Prescription Drug Benefits with State Pharmacy
Assistance Programs. New York, NY The
Commonwealth Fund, publication forthcoming. Inclu
des disabled persons enrolled in state-only
program. Enrollees in Illinois Senior Care
Pharmacy Plus waiver program are ineligible for
transitional assistance and the discount card.
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Number of States Mandating Enrollment in Medicare
during Discount Card Period

of States
Source Fox, K, Crystal, S. Coordinating Medicare
Prescription Drug Benefits with State Pharmacy
Assistance Programs. New York, NY The
Commonwealth Fund, publication forthcoming.
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States Strategies for Getting SPAP Eligible
Persons Enrolled

N10
Source Fox, K, Crystal, S. Coordinating Medicare
Prescription Drug Benefits with State Pharmacy
Assistance Programs. New York, NY The
Commonwealth Fund, publication forthcoming.
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State Strategies for Enrolling Members in
Transitional Assistance

• Autoenrollment in Preferred Card (8 states)
• Authorized representative status
• Expedited RFP or Expansion of Existing Contract
• Opt-out letters different methods for response.
• High participation rates in short period.
• Significant state savings reported
• Autoenrollment in Multiple Cards (1 state)
• Authorized representative status
• RFI to card sponsors data sharing agreement
• Opt-out letters
• Start-up delays, file-sharing inconsistencies
• High participation rates after 6 months.
• Savings still being determined.

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State Strategies for Enrolling Members in
Transitional Assistance (cont.)

• Facilitated Enrollment w/ Preferred Card (1)
• Expedited RFP or Expansion of Existing Contract
• Pre-populating applications
• Outcome - ?
• Voluntary Enrollment by Individual Members (6)
• Outreach varies.
• Letter to benes
• Use of SHIPs
• Outcome Much lower enrollment rates in states
  that had data from CMS.
• Minimal savings to state.
• Two states moving to autoenroll or facilitate
  enrollment due to low enrollment rates.
• Many of those enrolled are not using the 600
  credit.

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Use of Incentives by SPAPs to Encourage Enrollment

• State pays all or portion of the 5-10
  coinsurance (10 states)
• Preceded autoenrollment allowance.
• Post autoenrollment maintained to discourage
  opt-out.
• Outcome difficult to measure.
• Waiving other SPAP requirements
• Enrollment fees
• Counting 600 toward state deductible
• Waiving reapplication for SPAP during discount
  card period.
• Increasing SPAP Benefits
• Increasing benefit caps
• SPAP pays first, discount card used only if state
  does not pay
• Incremental impact of Incentives vs. other
  approaches unknown.
• Most states using incentives were also
  autoenrolling.

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Lessons from Efforts to Enroll Persons in
Medicare Savings Programs

• Community-based outreach important
• One-on-one assistance works best, but expensive
• Use of SHIPs
• Linking outreach/enrollment with other low-income
  benefit programs
• Combined outreach for TA, SPAP, and MSP
• Limiting administrative hassles can significantly
  impact enrollment
• Simplifying application and renewal processes
• Modifying eligibility and eliminating
  documentation requirements
• Implications for Part D more than Discount
  Card/TA
• Partnerships with Other Trusted Sources Helpful
• Deputization to allow these entities to help fill
  out applications and submit
• Kiosks at medical clinics.
• Mixed success with direct mail

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Summary of Enrollment Lessons from Discount Card

• Autoenrollment the most efficient mode for
  getting people enrolled.
• Transparent to enrollees.
• Nearly 100 of enrollment in transitional
  assistance is due to SPAP and MC autoenrollment.
• One application process for card and subsidy
  minimized burden.
• Will not be the case under Part D expect even
  lower enrollment in subsidies.
• Asset test requirement will also reduce
  participation in Part D subsidies.
• Left on their own, voluntary enrollment has been
  extremely low.
• Voluntary enrollment may be enhanced by offering
  incentives, but degree of impact unknown.

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Michael McMullan

• CMS Timeline

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Gale Arden

• Low Income Subsidy

17
Donna Boswell

• SPATC preliminary recommendations

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State Pharmaceutical Assistance Transition
Commission (SPATC)

• Snap Preview of SPATC Recommendations
• For NGA Part D Implementation Project
• December 16, 2004

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SPATC Charter in MMA

• Appointed by the Secretary to develop a proposal
  to advise the Secretary and the Administrator of
  CMS on ways to address the unique transitional
  issues facing SPAPs and SPAP participants
  consistent with the following principles
• Protection of the interests of program
  participants in a manner that is least disruptive
  to such participants and that includes a single
  point of contact for enrollment and processing of
  benefits.
• Protection of the financial and flexibility
  interests of States so that States are not
  financially worse off as a result of the
  enactment of this title.
• Principles of Medicare modernization under the
  MMA.

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Knowledge Through Experience

• SPATC members believe that the experience gained
  --
• (1) in administering SPAPs for Medicare
  beneficiaries over the last decade, and
• (2) in helping those beneficiaries deal with the
  Medicare drug discount cards
• should be used to inform the part D
  implementation and to avoid if possible--
  making the same missteps twice!

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SPATC ApproachFor Tackling Complex Issues

• The problems identified at the first meeting,
  July 8, 2004, were divided into three groups, and
  Commission members each served on one of the work
  groups
• 1) transition of current SPAP beneficiaries
  education, eligibility, and enrollment
• 2) benefit design/coordination of SPAPs with the
  new Part D program and
• 3) issues affecting the infrastructure of
  providers, systems, and data collection and
  management.

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Key Recommendations 1

• SPAPs should be considered authorized
  representatives of their beneficiaries for the
  purposes of determining their eligibility for
  subsidy assistance, enrolling them in one or more
  preferred PDP sponsors, and paying their Part D
  premiums.

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Key Recommendations 2

• To provide seamless and comprehensive benefits
  coordination, SPAPs should be allowed to choose
  preferred part D sponsors on behalf of their
  enrollees.
• SPAPs know their beneficiaries existing
  medications and can help select part D plan with
  appropriate formulary and cost sharing to assure
  that beneficiarys transition is smooth.
• The MMA anti-discrimination requirement can be
  met by ensuring that the SPAP provides equivalent
  subsidy to any of its beneficiaries that wishes
  to opt for a different part D plan.

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Key Recommendations 3

• The exceptions and appeals process, as proposed
  in regulations, should be revised-
• SPAPs should be given authority to appeal on
  behalf of beneficiaries, since the SPAPs are at
  financial risk for formulary denials and high
  tier copays.
• The process should provide denial and appeal
  rights notices and make the process timelines
  much quicker for the sake of consumer access and
  protection.

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Key Recommendations 4

• CMS should form an advisory committee of SPAP
  representatives and other stakeholders (like the
  SPATC) to assist and inform them through the
  transition of implementing Part D.

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Key Recommendations 5

• A Centralized Data System should be established
  to facilitate data exchange through a single
  entry point so that all involved parties have
  access to timely and accurate data needed
• for the real-time coordination of benefits
  (COB)
• For the tracking of TrOOP.

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Key Recommendations 6

• Marketing, enrollment, and educational materials
  should be appropriate to the beneficiarys
  situation, including
• Information about the availability of SPAP
  coverage in the State, and
• clear explanations of how the SPAP will
  coordinate prescription benefits with part D
  plans in the state.

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Key Recommendations 7

• CMS should ensure that SPAPs that do not wish to
  provide full secondary coverage can supplement
  the coverage offered by Part D plans coverage
  by
• Paying premiums for standard coverage
• Paying premiums for enhanced alternative coverage
• Paying a flat fee to reduce cost sharing by
  eliminating the deductible filling the donut
  hole or reducing the coinsurance, like the
  federal subsidy does for the lowest income
  beneficiaries, or
• Paying cost-sharing for drugs for specific
  diseases.

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Additional Questions

• Please use the dialog box beside the screen to
  send your questions to the speakers.