1. Medicare Part D Implementation Issues: Key Decisions for States
AcademyHealth & Rutgers October 7, 2004 Joan Henneberry

2. State Pharmaceutical Assistance Transition Commission
Created by MMA
Advise HHS
Develop a proposal
Submit report to Congress and President by 1/1/05
Advise Secretary and administrator of CMS on ways to address unique transitional issues facing SPAPs and their participants
Proposal must be consistent with principles of the modernization of Medicare as outlined in the MMA; protect interests of program enrollees to be least disruptive and include a single point of contact for enrollment and processing benefits; protect the interest of states so they are not financially worse off after enactment.

3. Composition of Commission
8 SPAPs
2 other state programs
3 MA/PBM
10 other
Rep from each subsidy SPAP
Other states with other SPAPS
Medicare advantage orgs, pbms, or health plans
Other – one consumer, 4 pharmacists, md, rn, jd

4. Subcommittees Beneficiary Transition Program Design Providers/Systems
Education, eligibility, enrollment
Coordination between PDPs, MAPDs and SPAPs
Infrastructure, data, evaluation

5. Lessons from Discount Card Transition
Education critical
Coordination can save state $
SPAPs as wrap-around
COB major concern
Outreach for pre-duals
Keep it simple for the recipient – auto enroll, new card, same copays with state wrapping around
NJ calculating a $90 million savings in 2005 by having seniors use the discount card first, then supplement
Can pay premiums, deductibles, and donut hole
WY and KS may get out of SPAP business
Simple vs complicated – simple is dollar amount subsidy – complicated is wrapping benefits and copays and if there are multiple PDPs then multiple coordination with formulary and networks, file transfer, etc.
COB – coordination of benefits of concern to everyone, especially pharmacies. Medicare, SPAP, manufacturer program – pharmacies will have greater role and need real time info – interested in using a standard benefit card
Prevention of spend down

6. Preliminary Recommendations
NPRM
Papers
Public Comment on 10/14/04
Contact Information
HHS Secretary Tommy G. Thompson today announced $125 million in grants to states to help educate low-income Medicare beneficiaries who currently get their prescription drugs through state-funded programs about the new Medicare drug benefit coming in 2006.
The funds were set aside in the Medicare Modernization Act (MMA) for grants to state pharmaceutical assistance programs (SPAPs) for fiscal years 2005 and 2006.  The amount each state operating an SPAP will receive is based on the number of participants enrolled in each program as of October 1, 2003 (subsidy not discount programs). Grants due 8/9.
1. Will CMS allow state pharmacy assistance programs (SPAPs) to use existing Medicaid income disregards and asset calculations in any auto-enrollment scenario?
2. What is the States’ liability for individuals who refuse to enroll in Part D and who are dually eligible for Medicaid and Medicare? Who pays for prescription drug benefits? Will CMS allow States to deny Medicaid drugs to dual eligibles but still cover drugs for non-duals? Will the Federal government still provide Medicaid matching funds to States? Can states force dual eligibles to enroll in Medicare Part D?