CMS Delays Enforcement of Medicare Part D Provider Enrollment to January 1, 2019

Centers for Medicare and Medicaid Services (CMS) has issued an announcement that it is delaying its Medicare Part D provider enrollment implementation until January 1, 2019 and will be using a phased-in pre-enrollment period, with extra outreach efforts to prepare prescribers for full implementation on January 1, 2019. CMS is responding to the mass confusion concerning its initial announcement that all prescribing health care professionals, including dentists, needed to be noted in the Medicare system in some manner for their patients’ prescription drug costs to be reimbursed by Medicare Part D. However, there were multiple conflicting ways to be noted in the Medicare system, — from completely opting out of Medicare, to fully enrolling in Medicare, to enrolling only for certain ordering/referring/prescribing purposes — all with different consequences for each option. As CMS did not do a good job of explaining any of these options and often appeared confused itself as to how these various statuses worked for dentists, it had little confidence that its entire enrollment implementation was making any sense and was worried that this could lead to many patients being unpleasantly surprised by sudden non-reimbursement for their prescription drug costs. Therefore, CMS granted a lengthy delay until January 1, 2019 to implement its Medicare Part D prescribing provider enrollment program.

 

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