Beware if your plan has already printed marketing materials for the upcoming annual enrollment period. A new Centers for Medicare & Medicaid Services (CMS) memo, released on Tuesday, provides Medicare Advantage and Part D sponsors with instructions for updating Part D member materials for contract year 2023.

The CMS memo is addressed to all prescription drug plans, Medicare Advantage-Prescription Drug Plans, and Section 1876 Cost Plans. It specifies that the plans must inform Medicare members about coverage changes to insulin and vaccinations that will take effect January 1, 2023, as part of the Inflation Reduction Act.

The agency wants to make sure that Medicare beneficiaries aren’t confused by information contained in communication materials. Plans must review all marketing material to make sure information and guidance related to coverage of insulin or vaccines are accurate.

The updated information must be included in Evidence of Coverage (EOC), Annual Notice of Change (ANOC), Part D Formulary, Summary of Benefits, Websites, and other communications. The language must include information about what members will pay for insulin now that the law caps monthly co-pays at no more than $35 and update information or guidance related to coverage of insulin or vaccines.

The memo provides the exact language plans must include in communications and the timing of updates:

  • EOCs must be updated before being made available to enrollees by October 15. If it’s not practical to update already printed EOCs, CMS said plans may use the model EOC errata to communicate the information until the outdated materials are depleted. Enrollees must receive the EOC errata related to coverage of insulin or vaccines by November 15.
  • ANOCs must be updated before they are provided to enrollees by no later than September 30th. If hard copy ANOCs are already in print, plans may use the CY 2023 ANOC errata model until current stock is depleted and must be delivered by November 15.
  • Part D Formularies must be updated and provided to beneficiaries by October 15. If updates aren’t practical because they’ve already printed, CMS said plans may send enrollees a notice of formulary change that corrects information about insulin or vaccines by November 15.
  • Summary of Benefits must be updated and made available by October 15. If they are already in print, plans may use an addendum to fix inaccurate or inconsistent information or guidance related to coverage of insulin or vaccines until current stock is depleted.
  • Website content and materials must be updated by October 15.

For questions concerning the insulin and vaccine policy changes, contact PartDPolicy@cms.hhs.gov. For questions concerning required materials and enrollee communications, contact marketing@cms.hhs.gov.

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