New Web Site Provides Guidance on Part D

A new Web site was launched by APA and its partners last month to provide information about the new Medicare Part D prescription drug benefit. The site,<www.mentalhealthpartd.org>, is concerned with the issues faced by enrollees who need medication for mental illness and by their families. It also provides information for two groups to whom patients will turn for assistance in selecting a prescription drug plan (PDP): psychiatrists and other physicians and providers at community behavioral health and integrated health centers.

In addition to APA, the Web site is a joint effort of the National Mental Health Association, National Council for Community Behavioral Healthcare, and the Treatment Effectiveness Now project; it is also sponsored by these organizations, along with the American Association of Community Psychiatrists, National Alliance on Mental Illness, National Association of State Mental Health Program Directors, and American Association for Geriatric Psychiatry.

Irvin L. “Sam” Muszynski, J.D., director of APA's Office of Healthcare Systems and Financing, was a prime mover behind the creation of the Web site.

Said Muszynski, “We've been working with other mental health groups for over two years, originally to do what we could to affect how medications for mental illness would be dealt with under Part D, and later to determine what we could do as a coalition to help our various constituencies cope with the changes that Part D will bring. A Web site seemed like the best way to keep everyone apprised of the latest information as it becomes available and to have a central place where clinicians can find provider decision support tools.”

Muszynski noted that the coalition was apparently successful in getting the Centers for Medicare and Medicaid Services (CMS) to provide special protections for coverage of medications used to treat mental disorders. Antidepressants, antipsychotics, and anticonvulsants are among the six categories of medications that CMS has said should be represented on all PDP formularies by “all or substantially all” of the medications available. For other categories, PDPs are required to have only two drugs available in each.

Muszynski warned that “all or substantially all” may prove to be less inclusive than it sounds. He noted that CMS made it clear that this means that “all or substantially all” of the medications available must appear on each formulary in some form or other—it does not mean that every dosage and form of each medication have to be available. “We are hopeful that the actual formularies will match CMS's intent,” said Muszynski.

On the up side, CMS made it clear in meetings with APA that PDPs are to assume that Part D enrollees who seek refills for drugs under their new drug coverage have been stabilized on their current regimen and should continue to be provided with these necessary drugs regardless of their formulary status. Again, Muszynski warned that this directive may not be quite as good as it sounds because CMS has not codified it, and it is unclear how it will be enforced.

In mid-October, the official Medicare Prescription Drug Plan Finder went live at<www.medicare.gov>. If you scroll down the homepage, you will find the options “Compare Medicare Prescription Drug Plans” and “Formulary Finder.”

The option “Compare Medicare Prescription Drug Plans,” also known as the Plan Finder, allows you to conduct either a personalized search for apppropriate PDPs for a specific patient by entering that patient's Medicare information or to conduct a general search that produces a list of available plans in your region. One search method does not appear to be superior to the other. At press time, neither option allowed a patient's current drugs to be entered.

The Formulary Finder allows you to enter the name of the state and the list of medications the patient is taking. It then produces a list of the available plans that will provide all or some of those drugs.

When the Plan Finder became operational on October 17, it was clear that it was still very much a work in progress—it was unable to do many of the comparison tasks it was supposed to perform before November 15, the date that enrollment begins. It is hoped that CMS will rectify the problems soon.

Muszynski recommends that filling out the patient portion of APA's Patient/PDP Assessment Form (available at<www.mentalhealthpartd.org>) will prove helpful in making the best use of the Plan Finder when it works properly. The form helps psychiatrists compile a complete list of the medications a patient is taking. This information can then be fed into the Plan Finder or Formulary Finder, which should produce a list of the PDPs that can provide all (or substantially all) of the patient's drugs. and another list that can provide a portion of them.

The transition to drug coverage under Part D promises to be most problematic for dual-eligible beneficiaries, that is, those who are now receiving their medications through state Medicaid programs but will be switched on January 1 to coverage under a low-premium Medicare PDP. The Office of Healthcare Systems and Financing is surveying low-premium plans with national coverage to identify the status of commonly used brand-name psychiatric drugs. Although dual eligibles will be autoenrolled into a low-income plan in their region, they have the option of selecting another plan that will better meet their needs. Unlike other enrollees, who may change plans only during open enrollment periods, dual eligibles and other enrollees who receive low-income subsidies may change plans at any time. If they select a plan that costs more than the subsidy provides, they will be expected to pay the difference, which will likely require charitable assistance.

Since Medicare Part D appears to be a work in progress—it's not just the Web site that's changing daily—APA will be monitoring the program carefully during its initial enrollment period and after the program begins in January to determine whether CMS is making good on its promises to enrollees with mental disorders.

Muszynski reports that APA has sent a letter to CMS asking officials to resolve problems in accessing plan information online and recommends checking in at<www.mentalhealthpartd.org> to keep up with the latest information. ▪