Automatic Mailing for Part D Patients

As a follow up to the August 2022 Newsline article, Medication Synchronization: Possible Concerns we want to remind pharmacies of some specific requirements when automatically mailing refills to Medicare Part D patients. CMS first outlined requirements for auto-shipping refills in the 2014 Call Letter and most recently made revisions in the 2020 Call Letter – these requirements were implemented in response to beneficiary complaints of receiving medications that they did not order or want and to reduce waste and unnecessary cost to both patients and taxpayers.

Here are the important points from the 2020 Call Letter:

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Automatic shipping of refills must be voluntary
Affirmative consent is NOT required prior to shipping each refill if the pharmacy provides the following protections
1. Enrollment in auto-shipping is done on a drug-by-drug basis after an initial fill
2. Patients may opt-out at any time
3. Pharmacy provides a minimum of two shipping reminders before each fill
  1. Reminders should include the name of the medication, approximate ship date, information to determine the cost-share amount and how to cancel
4. Pharmacy must provide a refund for any unwanted fills
  1. This must occur even if the patient does not return the medication to the pharmacy

PAAS Tips:

The Call Letter requirements only apply to Medicare Part D prescriptions that are automatically shipped and do not apply to med sync prescriptions that are picked up at the pharmacy
Caremark and Express Scripts Provider Manuals mirror the 2020 Call Letter guidance for Medicare Part D

Author
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Eric Hartkopf, PharmD

Analyst at PAAS National^®

As an Analyst, I focus on providing pre- and post-audit assistance, answering various member service questions, and researching & drafting articles for the Third-Party Newsline. I work with many of our members involved with invoice audits.

I obtained my PharmD from the University of Wisconsin-Madison School of Pharmacy and worked for a major chain as well as various LTC and independent pharmacies, before coming to PAAS.

I am passionate about learning and teaching. I strive to learn something new about PBM audits every day, so that PAAS can be more knowledgeable to better serve our members! In 2018, I started traveling to state pharmacy conferences to present audit seminars and meet our wonderful members in person.

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