The significant differences in official long-term projections, including projections of the program’s unfunded liability, reflect the differences in agency assumptions, particularly about the likelihood of the continuation of current law. The Medicare Trustees and the Congressional Budget Office (CBO) are required to make projections under current law, which assumes, for example, that the large Medicare Part A payment reductions are sustainable and that the projected 29.4 percent reduction in Medicare physician payment will be implemented in 2012. The Office of the Actuary in the Centers for Medicare and Medicaid Services (CMS) makes projections based on the premise that key elements of current law are simply “unworkable.” See John D. Shatto and M. Kent Clemens, “Projected Medicare Expenditures Under an Illustrative Scenario with Alternative Payment Updates to Medicare Providers,” Centers for Medicare and Medicaid Services, Office of the Actuary, May 13, 2011, at https://www.cms.gov/ReportsTrustFunds/downloads/2010TRAlternativeScenario.pdf (September 19, 2011).
2015 Medicare Part D Program Compared to 2014, 2013, 2012 and 2011
Proposal in the 2015 Advanced Notice: This rule proposes to revise the definition of negotiated prices to require all price concessions from pharmacies to be reflected in negotiated prices. The proposed rule would provide greater cost savings for beneficiaries in return for offering preferred cost sharing so that sponsors cannot incentivize use of selected pharmacies, including the sponsors’ own related-party pharmacies that charge higher rates than their competitors. Also, CMS may request that Part D plans increase the number of pharmacies offering preferred, or lower, cost sharing as CMS is concerned that some plans that offer preferred cost sharing do not provide beneficiaries with sufficient access to the lower cost sharing at select network pharmacies. The intent of this policy will be to ensure that beneficiaries are not misled into enrolling in a plan only to discover that they do not have meaningful access to the advertised lower cost sharing. From the 2015 Announcement: Although we [CMS] are not adopting any network adequacy standards at this time, sponsors should be aware that we are continuing to monitor beneficiary access to preferred cost sharing in plans that purport to offer it. For the 2014 and 2015 plan years, we [CMS] will continue to review the retail networks of plans offering preferred cost sharing and will continue to take appropriate action regarding any plan whose network of pharmacies offering preferred cost sharing appears to offer too little meaningful access to the preferred cost sharing. For instance, a stand-alone PDP that offers preferred cost sharing at only seven pharmacies in a PDP region may be asked to increase the number of pharmacies offering preferred cost sharing or to restructure its benefit design during the bid negotiation process. The intent of these negotiations will be to ensure that beneficiaries are not misled into enrolling in a plan only to discover that they do not have meaningful access to the advertised lower cost sharing. We [CMS] note that beginning in 2015, we [CMS] will no longer use the terms "preferred" and "non-preferred" to describe network pharmacies, but rather will describe such pharmacies as offering standard or preferred cost-sharing.