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Delays By The CMS in the Medicare Part D Enrollment Requirement

An announcement was made by CMS that a delay for enforcing all prescriber regulations for Medicare Part D until January 1st, 2019. Finalized in May 23rd, 2014 Part D and Medicare Advantage Final Rule, this requirement only allows Medicare enrolled providers or any providers which have been granted a valid opt out affidavit that was issued by a Part B MAC or Medicare Part A to prescribe under Medicare Part D, a covered drug reimbursable. See original e-alert on May 23rd, 2014 Final Rule by Holland & Knight’s.

November 1st, 2016, an announcement was made by CMS to have a (Phased Approach) Part D prescriber enrollment until January 1st, 2019, then fully enforcing the prescriber enrollment requirement. Previously this mandatory prescriber enrollment requirement has been delayed up to 4 times even though it has been codified. While cited the need to help minimize any impact on beneficiaries as well as aligning enforcement of the prescriber enrollment requirements with the other CMS initiatives. Yet additional guidance on requirements for this phased approach were never issued. Now has announced a phased approach for Part D prescriber enrollment will not be implemented before January 1st, 2019.

While requirements for Part D prescriber enrollment to get reimbursements under Part D, continued encouragement for voluntary prescriber enrollment in Medicare by CMS. Continuous monitory for any guidance by CMS is done to gain additional guidance for the requirement or additional delay notifications. Further details can be found when checking the webpage for CMS Part D Prescriber Enrollment.