Medicare Program; Changes to the
Requirements for Part D Prescribers (CMS-6107-IFC)
2015-07-08 2015-07-08 2015-07-08
CMS-2015-0063-0006 CMS-2015-0063-0010 CMS-2015-0063-0012
04:00:00 04:00:00 04:00:00
https://api.regulations.gov/v4/comments/CMS-2015-0063-0006 https://api.regulations.gov/v4/comments/CMS-2015-0063-0010 https://api.regulations.gov/v4/comments/CMS-2015-0063-0012
Anonymous Anonymous Anonymous
Anonymous Anonymous Anonymous
Catamaran appreciates the opportunity to comment on the interim final rule with comment period, Medicare Program; Changes to the Requirements for Part D Subscribers, as published in the Federal Register on May 6, 2015.  Catamaran, the industrys fastest-growing pharmacy benefits manager, helps organizations and the communities they serve to take control of prescription drug costs. We manage more than 400 million prescriptions each year on behalf of 35 million members. Our flexible, holistic solutions improve patient care and empower individuals to take charge of their health. In addition, Catamarans skill and scale deliver compelling results and sustainable improvements in the overall health of our members. After a careful review of the proposed guidance, and discussion with other industry and Medicare Part D stakeholders, Catamaran is supportive of the comments provided by the Pharmaceutical Care Management Association. We appreciate the opportunity to comment and look forward to your feedback regarding this matter. RelayHealth Prospective Health Services appreciates the opportunity to comment on CMS-6107-IFC.  Prospective Health Services is an active member of NCPDP and fully supports the comments that they are submitting.  Our main concerns mirror what is detailed in the NCPDP letter and include the following:1.There needs to be a publically available listing of Other Authorized Providers to ensure consistency within the industry and less interruptions in service. 2.The provisional fill will create more confusion and there is not sufficient time to implement the logic effectively by 6/1/2016.  3.There is insufficient time to implement all of the new logic necessary by 6/1/2016.  There are still too many outstanding questions on many pieces of the logic including the Other Authorized Providers, the provisional fills, the member notifications, and PDE Edits.  In addition the timeframe is insufficient to implement new NCPDP code values. CMS-6107-IFCDoes CMS intend to provide model letters that plans will use to notify beneficiaries and prescribers when the prescriber is not enrolled with Medicare?