Thank you for inviting me to share my comments relating to Part D. Here they are:

1. CMS has not given any special considerations to Special Needs Plans (SNP) as Part D sponsors. All the formulary and reporting requirements are the same as they are for all the other Plans targeting the general Medicare population. In part, this is due to CMS' limited resources, which do not allow special consideration to take place. SNPs are, by definition, small plans targeting a population with special needs. Formulary structure should be expected and permitted to be different from a Part D formulary targeting the general Medicare population. At least the SNP should have more discretions for Prior Authorization procedures, for instance, because the SNP has the unique knowledge and experience to decide. To date, CMS requires all formulary structure to conform to one size, which can put a strain on the resources of a SNP.

2. CMS has a massive program to run and execute and its resources are limited. Nevertheless CMS has not given the same consideration to other Part D sponsors, many of which are new programs and are also limited in resources. Economically new Part D sponsors cannot staff up and incur enormous administrative expenses that may not be allowed by CMS in the bid. This may not change in 2008 as sponsors may come and go. Lack of consideration typically comes in the form of a 72 hour turnaround for responses regardless of the calendar days. For CMS, weekends and holidays are always off-limits. This puts immense strain on the staff of the sponsor and it is widely known that plans are experiencing staff turnover because of the demand of Part D. Ultimately, staff turnover at the plan level can jeopardize Part D's smooth operation.

3. Given the complexity of Part D especially with respect to risk adjustment,TrOOP, COB and reporting requirements, CMS should allocate more resources to plans to sort through their queries. In 2006 risk score (RxHCC) of the enrollees and their relationship to the capitation payment for Part D is not clear to some Part D sponsors. That was not explained very well in the training sessions and not a subject to be elaborated on the User Conference calls. It seems that that knowledge resides within a small group of specialists within CMS. The mechanism and rationale should be disseminated clearly so that Plans can track their memberships to ensure that they are not "short-changed" in terms of monthly premiums. This is just one illustration of limited/incomplete communication from CMS to the plans.

Sincerely,