CMS released two time-sensitive HPMS memos on September 6, 2022:  

  1. Updates to Part D member materials for Contract Year (CY) 2023 
  2. Additional Part D updates to CY 2023 Member Material Models for Medicare-Medicaid Plans  

These changes impact Part D sponsors, Medicare Advantage and Part D sponsors, Medicare-Medicaid Plans, and Minnesota Senior Health Options plans for the upcoming Annual Enrollment Period (AEP). 

The Inflation Reduction Act of 2022 was signed into law on August 16, 2022 and contained two key provisions that go into effect January 1, 2023: 

  • Section 11401 (Coverage of Adult Vaccines Recommended by the Advisory Committee on Immunization Practices Under Medicare Part D) 
  • Section 11406 (Appropriate Cost-Sharing for Covered Insulin Products Under Medicare Part D) 

It’s important that Medicare enrollees understand how these changes affect Part D coverage.   

CMS made changes regarding insulin and vaccine language to ensure Medicare beneficiaries receive accurate information and are not confused by communication and marketing materials, including plan websites.  

What should plan sponsors do? 

  • Complete required language changes to Annual Notice of Changes (ANOC), Explanation of Coverage (EOC), Member Handbook, Formulary/List of Covered Drugs, Summary of Benefits and plan websites regarding new insulin and vaccines language as outlined in the released HPMS memos 
  • Review all communications and marketing materials to ensure information related to insulin and vaccine coverage is consistent with Part D benefits as provided under Section 11401 and 11406 of the Inflation Reduction Act of 2022. 

The following documents must be provided to current enrollees by the dates listed below: 

Communication/Marketing Material Due Date 
ANOC September 30  
EOC (hard copy or electronic) October 15 
Member handbook  October 15 
Part D formulary October 15 
Summary of Benefits October 15 
Website  October 15 
Errata Documents (ANOC, EOC, member handbook), if needed November 15 

Contact ATTAC Consulting Group to discuss how our experts can assist your plan to ensure your communications and marketing materials are accurate and compliant.