Comment letter to CMS addressing observations and recommendations for the operation and implementation

March 21, 2007 Ms. Abby Block Director, Center for Beneficiary Choices Centers for Medicare and Medicaid Services 7500 Security Boulevard Baltimore, MD 21244-1850 Subject: Medicare Part D – Lessons Learned Dear Ms. Block - In December 2003, the passage of the Medicare Modernization Act (MMA) resulted in the addition of a new “Part D” to the Medicare program to provide pharmacy benefits. The MMA reflected many compromises and new ideas for managing Part D, including extensive involvement of the private market. The year 2006 was the first year of operation for Medicare Part D, and the program was successful in attracting health plans and other entities to participate and individuals to enroll. About 90 percent of Medicare beneficiaries had some type of drug coverage 1in 2006. The program also included many new administrative requirements and features. While some aspects of the program operated smoothly, others did not, leaving areas for improvement and fine-tuning. 2On behalf of the American Academy of Actuaries’ Part D Lessons Learned Work Group, I would like to offer the following observations of what has worked well and what has not. Based on those observations, this letter also offers recommendations to improve the overall operation and administration of the Part D program. Specifically, some of the areas needing additional refinement include the bidding process, management of eligibility, and coordination with Medicaid and with the ...