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OBSERVATIONS - June 12, 2008

Making Medicare Part D Work for Vulnerable Beneficiaries

Nearly two and a half years into the implementation of the Medicare Part D drug benefit, the policy community is still trying to figure out how to make the program work best for Medicare’s low-income beneficiaries.  Those challenges are examined in two recent reports from The Commonwealth Fund, which confirm the extraordinary difficulty of reaching this population and highlight the need for increased collaboration across the various sectors that impact this group. 

Medicare Part D: How Do Vulnerable Beneficiaries Fare? summarizes feedback from a survey of over 600 counselors, attorneys, program managers and others involved in assisting Medicare beneficiaries.  While respondents focused on the experiences of low-income Medicare beneficiaries during the first year of Part D implementation, the issues they raised are still relevant today:

  • The process of auto-enrollment into Part D plans for full dual eligibles (those enrolled in both Medicare and Medicaid) and “partial duals” (those enrolled in Medicare Savings Programs, which pay part of their Medicare costs) has had problems, including plan assignment not occurring, pharmacies not having records of assignments, or beneficiaries being assigned to more than one plan.  Those surveyed felt that a substantial portion of these problems took more than a month to resolve or may have remained unresolved, and that auto-enrollment problems often led beneficiaries to experience delays in getting drugs they need. 
  • Access to prescription drugs has been hindered by assignment of low-income beneficiaries to Part D plans whose formularies may not have included all of their drug regimens (though they may have covered an equivalent drug), and lack of awareness among beneficiaries about their right to file an exception request or an appeal to gain coverage of needed drugs or of the ability of dual eligibles to switch plans at any time.
  • Respondents felt that lower-than-desired enrollment in the Part D Low-Income Subsidy (LIS) reflects lack of awareness of the benefit, lack of understanding of how to apply for the program, assumed ineligibility for financial reasons, and a complicated enrollment process. 

This last aspect, access to the LIS, is part of the focus of Medicare Part D: State and Local Efforts to Assist Vulnerable Beneficiaries,which reviews a number of efforts across the country to help low-income beneficiaries obtain the Part D benefit.   State and local governments, as well as community and advocacy organizations, have worked in coalitions or on their own to educate others about the Part D benefit, to reach out to beneficiaries to help them sign up for Part D and to access the LIS when eligible, to facilitate easier enrollment processes for the LIS, and to address the unique needs of beneficiaries with limited English proficiency. 

Both of these papers emphasize the critical roles of collaboration, education, and a comprehensive approach to the challenge of making the drug benefit work for the most vulnerable Medicare beneficiaries.  They highlight the need for attention to unintended consequences of program policies, and call out the benefits of diverse organizations working together to identify and address problems with outreach to and enrollment of low-income populations in Part D and the LIS benefit. 

While the Commonwealth Fund’s summary of successful practices focuses on state and local governments and advocacy organizations, health plans also can and do assist their Medicare members in receiving benefits for which they are eligible.  Kaiser Permanente (KP)  worked to fill this role by partnering with the National Council on Aging (NCOA) on an outreach campaign to identify KP members who qualified for the LIS, help them apply, and identify other public programs for which they might be eligible.  This effort was detailed in a KP Institute for Health Policy “In Focus” Brief in late 2007, highlighting KP’s approach, outcomes (including enrollment in LIS and other programs and the financial impact for members and the plan), lessons learned, and implications for policy.

Together, these three papers illustrate implementation challenges of well-intentioned legislation and regulation, and promising approaches for overcoming these challenges.  Clearly, no one entity – Medicare counselors, state and local agencies, community groups, health plans, or others – can overcome the barriers to supporting vulnerable Medicare beneficiaries alone.  But by focusing on the specific goal of ensuring low-income beneficiaries’ access to the prescription drugs they need, these entities are forming relationships and infrastructure that may help them achieve even broader supports – beyond prescription drugs – for this population.

- Kate Meyers, MPP, Senior Policy Consultant, KP IHP

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