1c – Crosswalk for Second Drug Management Program Notice

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

Letter heading/intro
What Action Have We
Taken?
Why Did We Make
This Decision?
Why Did We Make
This Decision?
What Happens Next?
For More Information
and Help with This
Notice
For More Information
and Help with This
Notice

Make verbiage about methods to contact more
general and corresponding changes to indicate
multiple ways to contact plan. Formatted section
headings.
Clarify intro language on action taken by prior Part
D plan
Insert "to medications" to clarify that only drug
access may be limited by DMPs
Insert new language on recent history of an opioid
overdose as a possible rationale for the plan's
decision on limitations
Include link for Medicare's webpage on pain
management
Insert additional appeal information about automatic
referral to independent reviewer
Include placeholders for plans to insert mailing
address, email address, and/or other methods of
contact
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.”

Type of
Change
Rev

Reason for change
Clarity, completeness

Burden
Change
No

Rev

Clarity

No

Rev

Clarity

No

Rev

Fulfill SUPPORT Act No
Requirements

Rev

Completeness

Rev

Fulfill SUPPORT Act No
Requirements
Completeness
No

Rev
Rev

No

Commenter
No
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

For More Information
and Help with This
Notice

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

Pharmacy and
Prescriber Selection
Form

Add verbiage so that member choices do not imply
Rev
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 Rev
prescriber selection form is optional when there is
no intended pharmacy or prescriber limitation.

Pharmacy and
Prescriber Selection
Form
End of document

Moved disclaimer to above optional portion of letter

Rev

Rev

Commenter
recommendation
during 60-day
comment period to
protect privacy of
clinical staff
Clarity, completeness

No

Clarity

No

No

Commenter
No
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.