On January 6, 2022, the Centers for Medicare and Medicaid Services (CMS) released a proposed rule regarding Contract Year 2023 Policy and Technical Changes to the Medicare Advantage and Medicare Prescription Drug Benefit Programs, marking the Biden administration’s first proposed rule on these topics. The proposed rule includes proposed changes to the manner in which pharmacy price concessions are accounted for in the Part D benefit, the timing of network adequacy reviews for Medicare Advantage Organization (MAO) applicants, and new rules regarding oversight of third-party marketing organizations. The proposed rule also reverses course on some policy changes that were initiated under the prior administration, including changes related to medical loss ratio (MLR) reporting and past performance evaluations. The proposed rule includes proposed policy updates for Dual Eligible Special Needs Plans (D-SNPs) and a few provisions related to the ongoing COVID-19 public health emergency (PHE).
Proposed Rule on MA and Part D Would Reinstate Historical Requirements, Make Changes to Prescription Drug Payment Structure
By Kate McDonald, Mara McDermott, Ankur J. Goel, Emily Curran, Taylor Hood and Haile Dagne on March 3, 2022
Posted In Employee Benefits, Health and Welfare Plans
Tags: Biden administration, Centers for Medicare and Medicaid Services, Contract Year 2023 Policy and Technical Changes, COVID-19, Dual Eligible Special Needs Plans, medical loss ratio, Medicare Advantage, Medicare Advantage Organization, Medicare Prescription Drug Benefit Programs, pandemic, Part D
Kate McDonaldKate McDonald represents clients across the healthcare industry on complex regulatory matters and high-stakes mergers and acquisitions, affiliations and other investments. She delivers strategic advice on federal and state laws applicable to health insurers and HMOs, including the downstream implications for their provider organizations and vendors, as well as the reimbursement landscape of federal healthcare programs. Kate serves as partner-in-charge of McDermott’s healthcare practice in Washington, DC. Read Kate McDonald's full bio.
Mara McDermottMara is an accomplished health care executive with a deep understanding of federal health care law and policy, including delivery system reform, physician payment and Medicare payment models.Read Mara McDermott's full bio.
Ankur J. GoelAnkur J. Goel represents health industry clients in significant compliance, False Claims Act, litigation and regulatory matters. Ankur works with a range of health industry clients. He represents health plans on issues arising under Medicare Advantage, Part D, and health insurance exchanges, as well as health care providers on a variety of complex enforcement, compliance, regulatory and litigation matters. Read Ankur Goel's full bio.
Emily CurranEmily R. Curran focuses her practice on healthcare regulatory and compliance issues in the managed care space. She counsels both for-profit and non-profit healthcare insurance companies on state and federal policy issues and advises clients on reimbursement issues that come into play when participating in government healthcare programs. Emily also supports the Firm’s transactional work. Read Emily Curran's full bio.
Taylor HoodTaylor Hood advises healthcare companies on a variety of litigation, regulatory and healthcare policy matters. Taylor focuses his practice on issues that arise in the managed care sector for both payors and providers, including provider payments, health benefits and insurance practices. He also counsels clients in arbitration and before state medical boards, with experience before the Texas Medical Board. With a particular emphasis on the Texas market, Taylor also supports the Firm’s transactional work by assisting healthcare clients and investors in structuring and executing transactions. Read Taylor Hood's full bio.
Haile DagneIn today’s ever-changing healthcare environment, Haile helps clients tackle important market access issues, focusing on strategies to obtain coverage, coding, and appropriate payment for novel medical technologies, including medical devices, diagnostics and drugs/biologicals. He draws on his deep background analyzing regulatory and legislative policy on novel medical technologies and value-based care issues to advise on barriers and opportunities for clients across a diverse healthcare spectrum. Read Haile Dagne's full bio.
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