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July 18, 2024
On April 15th, CMS released a memo entitled ‘Submitting Other TrOOP Amount Information for 2023 Part D Payment Reconciliation of the Inflation Reduction Act Subsidy Amount (IRASA)’. This memo provided guidance to Part D sponsors on the process and file formats required to reconcile Inflation Reduction Act Subsidy Amounts (IRASA) during the 2023 Part D Payment Reconciliation. The associated file formats are detailed in attachments and posted online.
The Inflation Reduction Act of 2022 introduced changes to Medicare Part D, effective January 1, 2023. These changes include cost-sharing maximums for covered insulin products and ACIP-recommended adult vaccines. For 2023, CMS indicated they would provide a retrospective Inflation Reduction Act Subsidy Amount (IRASA) to cover these costs as bids were already submitted for this plan year. The IRASA amount was defined as the difference between the actual beneficiary cost sharing and the statutory maximum ($35 for insulin, $0 for vaccines). This amount applied toward the enrollee’s TrOOP and was reported in the ‘Other TrOOP Amount’ field on the Prescription Drug Event (PDE) record.
Starting this week, Part D Sponsors will receive Report 45, which provides detailed information on accepted PDE records that reported a “B” in the Other TrOOP Amount Indicator field. A value of “B” within this field indicates that the amount reported in Other TrOOP field contains both IRASA and non-IRASA Other TrOOP amounts. Plan Sponsors must intake this report, append additional information to calculate the actual IRASA amount on the PDE record, and upload a newly created Report 46. CMS will then provide Report 47 which will indicate if the records on Report 46 were accepted or rejected.
The final date to submit Report 46 is by September 30, 2024. It is advisable to complete this activity prior to year-end activities have kicked off. BluePeak is prepared to assist plans in all PDE activities, including converting these reports into readable formats and creating the submission report into CMS. Please reach out to us for any PDE support or assistance with completing this activity prior to the CMS deadline.
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