Court Vacates Coupon Cost-Sharing Rule

Ed MacConnell

On September 29, 2023, a significant legal development occurred that could affect how health insurance carriers and group health plans handle manufacturer coupons for prescription drugs. The District Court for the District of Columbia vacated a rule issued by the Department of Health and Human Services (HHS) that allowed, but did not mandate, the inclusion of manufacturer coupons in calculating the cost-sharing for health plans. In this blog post, we’ll explore the background of this issue, the 2019 HHS rule, and the subsequent legal decisions that have led to this recent development. HHS’s 2019 Rule In 2019, HHS issued a rule to clarify this matter. The rule stated that plans… Read More

Continue Reading

What Does the Medicare Part D Benefit Look Like in 2023?

Ed MacConnell

The standard design of the Medicare Part D benefit currently has four distinct phases, where the share of drug costs paid by Part D enrollees, Part D plans, drug manufacturers, and Medicare varies (Figure 1). (The Part D enrollee shares reflect costs paid by enrollees who are not receiving low-income subsidies.) If you have any questions or concerns please contact your Total Benefit Solutions, Inc Medicare health insurance specialist at (215)355-2121.

Continue Reading

Additional Guidance on New Prescription Drug Reporting Requirement

Ed MacConnell

As previously reported in 2021, Section 204 of the Consolidated Appropriations Act, 2021 (“CAA”) requires plan sponsors of group health plans to submit information annually about prescription drugs and health care spending to Centers for Medicare and Medicaid Services (“CMS”) on behalf of the Departments of Health and Human Services (“HHS”), Labor (“DOL”), and the Treasury (collectively, the “Departments”). The first deadline is December 27, 2022. CMS recently updated guidance related to this reporting requirements that proves some helpful clarification. Have any questions regarding this notice? Please contact your Total Benefit Solutions health insurance specialists today at (215)355-2121.

Continue Reading

Additional Guidance on New Prescription Drug Reporting Requirement

Ed MacConnell

As previously reported in 2021, Section 204 of the Consolidated Appropriations Act, 2021 (“CAA”) requires plan sponsors of group health plans to submit informationannually about prescription drugs and health care spending to Centers for Medicare and Medicaid Services (“CMS”) on behalf of the Departments of Health and Human Services(“HHS”), Labor (“DOL”), and the Treasury (collectively, the “Departments”). The first deadline is December 27, 2022. CMS recently updated guidance related to this reporting requirement that provides some helpful clarification. Click the link below to download this bulletin. As always please contact your Total benefit Solutions, Inc health insurance specialist at (215)355-2121 if you have any further questions or concerns.

Continue Reading