Medicare Part D: Enrolling New Dual-Eligible Beneficiaries in Prescription Drug Plans Page: 4 of 15
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interviewed officials from CMS and representatives of PDPs about issues
that pertain to dual-eligible beneficiaries. We conducted the work for our
report from March 2006 through April 2007 in accordance with generally
accepted government auditing standards.
In summary, we found that CMS's process for enrolling new dual-eligible
beneficiaries involves many parties, information systems, and
administrative steps, and takes a minimum of 5 weeks to complete. For the
majority of these individuals-generally Medicare beneficiaries not yet
enrolled in Part D who subsequently qualify for Medicaid-this processing
interval can create difficulties in obtaining Part D-covered drugs at their
pharmacies. For other new dual-eligible beneficiaries-Medicaid enrollees
who become Medicare eligible because of age or disability-CMS took
steps to eliminate the impact of the processing interval by enrolling them
in PDPs just prior to their attaining Medicare eligibility. In addition, for the
Medicare first, Medicaid second group of new dual-eligible beneficiaries,
CMS set the effective date of Part D coverage to coincide with the first
date of their Medicaid eligibility. Under this policy, which was designed to
provide drug coverage for dual-eligible beneficiaries as soon as they attain
dual-eligible status, the start of their Part D coverage can be retroactively
set to several months before the date of their actual PDP enrollment. We
found that CMS did not fully implement or monitor the impact of this
coverage date policy. Although beneficiaries are entitled to reimbursement
for covered drug costs incurred during this retroactive period, CMS and
PDPs did not begin informing them of this right until March 2007. Also,
CMS did not track Medicare payments made to PDPs to provide
retroactive coverage or monitor PDPs' reimbursements to beneficiaries for
that time period. We estimate that in 2006, Medicare paid PDPs about
$100 million for coverage during periods for which dual-eligible
beneficiaries may not have sought reimbursement for their drug costs. In
the report, we recommend that CMS require PDPs to notify beneficiaries
about their right to reimbursement, monitor implementation of its
retroactive payment policy, and take other steps to improve the
operational efficiency of the program.
Background Dual-eligible beneficiaries are a particularly vulnerable population. These
individuals are typically poorer, tend to have far more extensive health
care needs, have higher rates of cognitive impairments, and are more
likely to be disabled than other Medicare beneficiaries. About three out of
four dual-eligible beneficiaries live in the community and typically obtain
drugs through retail pharmacies. Other dual-eligible beneficiaries reside in
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United States. Government Accountability Office. Medicare Part D: Enrolling New Dual-Eligible Beneficiaries in Prescription Drug Plans, text, May 8, 2007; Washington D.C.. (digital.library.unt.edu/ark:/67531/metadc292754/m1/4/: accessed February 21, 2019), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.