1b – Crosswalk for Initial Drug Management Program Notice

Crosswalk for Initial Drug Management Program Notice
2018 (old version)
2021 (new version)
Throughout
Introduction

Make verbiage about methods to contact more general
and corresponding changes to indicate multiple ways
to contact plan. Formatted section headings.
Clarified start date of limitation to be “as early as” the
given date, rather than an absolute date.

Type of
Change
Rev

Reason for change

Rev

Commenter
recommendation
during 60-day
comment period to
improve enrollee
communication
since the limitation
may not take effect
exactly 30 days
from the initial
notice
Commenter
recommendation
during 60-day
comment period to
improve enrollee
communication
Fulfill SUPPORT
Act requirements
Clarity

No

Consistent with
4190-F2 regulatory
provision
Clarity,
completeness

No

What Action Do We
Intend to Take

Removed an absolute date of limitation and rephrase
to clarify that the limitation may be put in place if
additional information is not provided

Rev

What Is A Drug
Management Program
What Is A Drug
Management Program
What if I Don't Agree?

Include recent history of opioid overdose as third
example of when risks from opioids are increased
Insert "under our drug management program" at end

Rev

Add sickle cell disease exemption

Rev

What if I Don't Agree?

Insert language referring to rationale for contact and
contact options in other section

Rev

Rev

Clarity,
completeness

Burden
Change
No

No

No
No

No

2018 (old version)

2021 (new version)

What If I Don’t
Agree?

Change “cancer” to “active cancer-related pain”

What Happens Next

Moved “You will also receive another notice if we
Rev
decide you’re not at risk and will not limit your access
to these drugs” to earlier in section. Added “drug
access” instead of “access.”
Insert additional appeal information about automatic
Rev
referral to independent reviewer.
Include link for Medicare's webpage on pain
Rev
management

What Happens Next?
What Resources Are
Available to Help Me
Use My Medications
Safely?
For More Information
and Help with This
Notice

Include placeholders for plans to insert mailing
address, email address, and/or other methods of
contact

Type of
Change
Rev

Rev

Reason for change

Burden
Change
No

Commenter
recommendation
during 60-day
commpent period to
align with
regulatory language
Clarity,
No
completeness
Fulfill SUPPORT
Act requirements
Completeness

No

Completeness

No

No

2018 (old version)

2021 (new version)

For More Information
and Help with This
Notice

Clarify that email address and/or other methods of
contact are optional by adding “If the plan has a
dedicated line (toll free), staff person, web portal, etc.
for its DMP, that information may be included in this
section, as applicable.”

For More Information
and Help with This
Notice

Do not include signature for letter including name and
credential of clinical staff

Rev

Pharmacy and
Prescriber Selection
Form

Add verbiage so that member choices do not imply
multiple pharmacies / prescribers will always be
selected by plan sponsor. Clarify that enrollees can
provide contact information for up to two pharmacies
and/or prescribers of their preference (does not have
to be exactly two).
Added instructions to indicate that the pharmacy and
prescriber selection form is optional when there is no
intended pharmacy or prescriber limitation.

Rev

Commenter
recommendation
during 60-day
comment period
since not all plans
utilize email or
alternate contact
methods and to
minimize new
variable fields that
may delay
programming ahead
of required
implementation
date
Commenter
No
recommendation
during 60-day
comment period to
protect privacy of
clinical staff
Completeness
No

Rev

Clarity

Pharmacy and
Prescriber Selection
Form

Type of
Change
Rev

Reason for change

Burden
Change
No

No

2018 (old version)

2021 (new version)

End of document

Moved disclaimer to above optional portion of letter

Type of
Change
Rev

Reason for change

Burden
Change
No

Commenter
recommendation
during 60-day
comment period to
avoid information
being excluded
from notice
INFORMATION NOT RELEASABLE TO THE PUBLIC UNLESS AUTHORIZED BY LAW: This pre-decisional,
privileged, and confidential information is for internal government use only, and must not be disseminated, distributed, or
copied to persons not authorized to receive the information. For Preliminary discussion only, pending review of all public
comments. Unauthorized disclosure may result in prosecution to the full extent of the law.