Premier Comments on CY 2025 MA and Medicare Part D Proposed Rule

Premier submitted comments to CMS in response to the proposed rule for the MA and Medicare Prescription Drug Benefit (Part D) Programs for Contract Year 2025. The proposed rule seeks public comment on CMS’ proposals to ensure timely access to care, protect beneficiaries from predatory marketing practices, strengthen quality, advance health equity, improve access to behavioral health services and improve drug affordability and access in Part D.

In its detailed comments, Premier specifically recommends that CMS consider the following:

  • Expanding network adequacy data collection and monitoring to ensure beneficiaries’ access to care.
  • Tightening medical loss ratio (MLR) transparency requirements to strengthen accountability around the use of Medicare premium dollars for medical benefits.
  • Finalizing the proposal to permit Part D sponsors to treat formulary substitutions of biosimilar biological products other than interchangeable biological products for their reference products as maintenance changes that would not require prior approval by CMS.
  • Supporting the wider adoption of interoperable health information technologies across the spectrum of care, particularly in long-term care and post-acute care settings.
  • Finalizing the new National Council for Prescription Drug Programs SCRIPT standard 2023011 as the Part D electronic prescribing standard by Jan. 1, 2027 and to align electronic prescribing standards with the Office of the National Coordinator for Health Information Technology (ONC) regulations.
  • Setting the Electronic Prescribing of Controlled Substances implementation date to Jan. 1, 2027 so that it aligns with the overall electronic prescribing date.
  • Finalizing the adoption of the NCPDP Real-Time Prescription Benefit standard version 13.
  • Finalizing the adoption of the NCPDP Formulary and Benefit version 60.

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