Date Change & Phased Enforcement of Part D Prescriber Enrollment
Summary & Background
CMS published a final rule in May 2014 and an interim final rule in May 2015 addressing prescriber enrollment requirements in Medicare. Prescribers must be enrolled in an active status or validly opted out, except in very limited circumstances, in order for their written prescriptions to be covered under Part D. CMS previously announced that enforcement of the prescriber enrollment requirement would begin on February 1, 2017. While CMS is committed to the implementation of the prescriber enrollment requirements, CMS also recognizes the need to minimize the impact on the beneficiary population and ensure beneficiaries have access to the care they need.
To strike this balance, CMS will implement a multifaceted, phased approach that will align full enforcement of the Part D prescriber enrollment requirements with other ongoing CMS initiatives. Full enforcement of the Part D prescriber enrollment requirement will begin on January 1, 2019.
In the lead-up to the January 1, 2019 full enforcement date, CMS will begin phasing in targeted enforcement of the regulation and undertake the following incremental strategic actions designed to increase on-going prescriber enrollment, while protecting beneficiaries and the Medicare program.
- Precluded Physicians and other Prescribers- The prescriber enrollment requirement will be enforced with respect to prescriptions written by individuals who are currently excluded by the OIG, who are revoked by the Medicare program, or who are non-enrolled prescribers with a felony conviction within the last 10 years. (Implementation: Q2 2017)
- Easy Enroll Application Process- CMS will further ease the enrollment application process to enable prescribers to quickly enroll in Medicare for the purpose of prescribing Part D drugs. This process will allow prescribers to review, update, electronically sign and submit a pre-populated enrollment application online. (Implementation: Q2 2017)
- Targeted Risk-Based Prescriber Outreach- CMS will begin targeted, prioritized risk-based outreach and education. This prioritized approach will include direct mailings and coordination with the Part D plans to enroll prescribers of Schedule II drugs or a high volume of Part D drugs. (Implementation: Q2 2017)
- Direct Mailing to all Non-Enrolled Prescribers- CMS will send direct mailings via email and/or paper to all prescribers that are not enrolled in the program. In addition, direct mailing notifications will be triggered for unenrolled prescribers based on Prescription Drug Events. (Implementation: Q3 2017)
- Current Education and Outreach-CMS will continue with the current education and outreach efforts including such activities as stakeholder meetings and conferences, assembly meetings, and presentations. (Continuously on-going)
While the full enforcement date is January 2019, CMS encourages all physicians and eligible professionals who prescribe Part D drugs, but are not yet enrolled or validly opted out of Medicare, to enroll in the Medicare Program. Enrollment information is available at:
For more information, please visit: https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/MedicareProviderSupEnroll/Part-D-Prescriber-Enrollment-About.html