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April 28, 2021

Medicare Advantage and Medicare Part D 2022 Final Rule

This Briefing is brought to you by the Medicare Advantage and Part D Affinity Group of AHLA's Payers, Plans, and Managed Care Practice Group.
  • April 28, 2021
  • Robert J. Baudino , Baudino Law Group PLC
  • Sandra Durkin , Strategic Health Law
  • Andrea Hoyt , PharmD, Drake University JD/MPA Candidate 2021
  • Christopher Lim , Fresenius Medical Care North America
  • Talia Linneman , Dentons
  • Patrick Ouellette , Fresenius Medical Care North America
  • Lauren Haley , Strategic Health Law

On January 19, 2021, the Centers for Medicare & Medicaid Services (CMS) published a final rule (Final Rule) that codifies certain provisions proposed by the agency in a February 18, 2020 proposed rule (Proposed Rule). CMS issued a separate final rule on June 1, 2020 that codified other sections from the Proposed Rule; the January 2021 Final Rule addresses the remaining proposals. This article discusses several of the key requirements addressed in the Final Rule, including:

  • New sections stemming from the Substance Use Disorder Prevention that Promotes Opioid Recovery and Treatment for Patients and Communities (SUPPORT Act);
  • Changes to Medicare Part D, including changes in the Part D Income Related Monthly Adjustment Amount, specialty drug coverage, and the Real Time Benefit Tool;
  • Changes to the Medicare Advantage (MA) rewards and incentives programs;
  • Revisions to requirements for Special Needs Plans (SNPs);
  • New requirements from supplemental benefits; and
  • Revisions and updates to the Programs of All-Inclusive Care for the Elderly (PACE) under the Medicare and Medicaid programs.

Most of the provisions in the Final Rule will be applicable to coverage beginning January 1, 2022, unless otherwise noted by CMS.

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