Medicare post PHE: 90-day transition amendment

Overview 
Prime continues to prepare for the COVID-19 Public Health Emergency (PHE), which is set to expire on May 11. Below is an update on further guidance from the Centers for Medicare & Medicaid Services (CMS) on the 90-day transitions supply that was previously communicated in the April 19, 2023 client digest. In addition, included is and update to the Medicare transition benefit flexibility.

​​​​​90-day transition supply 
After reviewing guidance and awaiting clarification from CMS, Prime has determined that plans may continue providing up to a 90-day transition supply. Guidance requires at least a month’s supply of medication, and therefore a 90-day supply meets that requirement. Further, plans have attested in their Transition Attestation to provide at least a month’s supply. These pieces of guidance are what Prime used to make this determination:

• 42 CFR 423.120(b)(3)(iii) requires “at least an approved month’s supply of medication.”
• CMS-4182-F, after the rules for long-term care transition day supply were amended, states “provide as a minimum…an approved month’s supply.”

Prime’s recommendation is to leave the Transition benefit at 90-day supply in place for the remainder of 2023.  A mid-year change to Transition is likely to create more confusion and a negative member experience.

If clients are still interested in reverting to the minimum month’s supply or have additional questions, please reach out to your Prime client engagement representative by May 5th.

Medicare flexibilities
In this April 3, 2023 communication, Prime stated that this flexibility would be deactivated:

• Transition – 90 Day Supply including emergency fills

Prime now recommends that transition stay in place for 2023. Prime also provided a sample member communication regarding Medicare flexibilities. Member communications should be amended to reflect that transition will not be deactivated.

If you have questions, please contact your Prime Client Engagement representative.