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FIDA Part D Transition Policies

The Final Medicare Advantage Rule, published April 16, 2018 and effective Jan. 1, 2019, included updates that affect Medicare Part D Transition requirements. As a result of these updates, the transition fill days' supply will now be a month's supply for both the retail and long term care settings. The Centers for Medicare and Medicaid Services (CMS) expects that Contract Year (CY) 2019 transition policies will accurately reflect the updated requirements when submitted to CMS.

CMS notes that for New York's Fully Integrated Duals Advantage (FIDA) plans, this change will conflict with current provisions in FIDA three-way contracts, and reminds plans that federal regulations will take precedence for CY 2019. Plans should ensure that 2019 Plan Benefit Package (PBP) submissions and transition policies, which are due June 4, 2018, reflect the Final Rule.

The CMS communication is available here. Questions can be addressed to MMCOCapsModel@cms.hhs.gov.

Contact: Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841