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In this presentation, Barbara Coulter Edwards, Ohio Medicaid Director, discusses the significant challenges in implementing Medicare Part D, particularly for dual-eligible beneficiaries. Key issues addressed include the adequacy of the Part D formulary, transition challenges with non-Part D drugs, and the complexities of coordinating information across multiple systems such as SSA, Medicare, and Medicaid. The implications of low-income subsidy eligibility determinations and the need for better data sharing and technology updates are emphasized. The session highlights the potential impact on vulnerable consumers and the urgent need for readiness reviews.
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State Medicaid Challenges: Implementing Medicare Part D Barbara Coulter Edwards Ohio Medicaid Director October 7, 2004
Impact on Dual Eligibles • Full-benefit duals, QIs, SLMBs, QMBs are deemed eligible for full low income subsidy • Full-benefit duals will be auto-enrolled (when, which plans?) • Adequacy of Part D formulary; non-Part D drugs – transition challenges • Impact on other utilization (nfs, disease mgmt)
New Business Relationships Effective implementation of Part D for low income Medicare beneficiaries will require information sharing across multiple systems: • SSA and Medicare • SSA and Medicaid • Medicaid and Medicare (parts A, B,C and D!) • Medicaid and private plans • Medicaid and SPAPs • Medicaid and state insurance departments
Information Technology IT systems changes will be required: Data sharing with other entities New reporting formats Low income subsidy eligibility determinations - Will states use SSA application and process? Challenges: HIPAA (continued!) Shared data systems Competing priorities
Future Budgeting States are developing future budgets now, and we lack critical information: • “Clawback” payment amounts • ’03 base too high? • National inflation factors too high? • Enrollment impact on Medicaid - a “woodwork effect” for duals?
Current Resources States need time, money, and people to accomplish the significant changes required by MMA. Reality for states: >Years of budget cuts. >No new funding for state share of costs. >Competing state priorities (control costs!). >Not enough time allowed by MMA.
Will duals be harmed? • Medicaid Rx coverage stops 1-1-06, whether consumers, states, or PDPs are ready or not. • If states and PDPs aren’t ready, vulnerable consumers may be harmed. • Should CMS require states, PDPs to pass “readiness reviews” before implementing Part D?
CMS State Issues Work Group • SSA Interaction (subsidy application and enrollment outreach) • Coordination of Benefits (transition for duals) • Notice Requirements • Data Coordination • “Clawback” Calculation (alternative ’03 reporting)