On July 16, 2024, the Centers for Medicare and Medicaid Services (CMS) released the final Part 2 guidance related to the Medicare Prescription Payment Plan (M3P) program. Along with that guidance, CMS released revised M3P model documents based on feedback CMS solicited from the public.
Below is an overview of those M3P model documents, some modifications made, and images of each document after those revisions.
Likely to Benefit Notice
Plan sponsors send the Likely to Benefit notice to enrollees who they have identified will benefit from enrolling in the M3P program. The notice describes the program generally.
The revised notice contains mostly minor text modifications, though there are a few items to note:
- The revised notice notes in multiple locations that though members won’t pay at the pharmacy, they’re still responsible for the costs of those prescriptions. That statement was noticeably missing from the preceding document version.
- CMS added a new website – medicare.gov/prescription-payment-plan – where members can learn more about the program. The page isn’t active today, but we assume it will be by open enrollment.
You can review the revised notice below:
M3P Participation Request Form
Plan sponsors use the Participation Request Form to enroll beneficiaries into the M3P program. The form contains the data elements required to enroll a new participant.
The revised form includes new instruction text for plan sponsors and introductory text briefly describing the program for enrollees. The revised form removes the question asking if a member gets help paying for prescription drug costs like Medicare’s Extra Help, a State Pharmaceutical Assistance Program (SPAP), Indian Health Services, or other health insurance. Instead, the introductory text indicates the plan may not be the best choice for those who get help through those programs.
The revised notice is below:
Part D Sponsor Notice to Acknowledge Acceptance of Election
Plan sponsors send the Acceptance Notice to enrollees to inform them that their election request has been processed and is effective. It also includes information about the billing process, paying for prescriptions, and how to disenroll.
The revised form includes additional information for plan sponsors and revised text. Among the changes:
- Like the Likely to Benefit notice, CMS added a sentence indicating that enrollees must pay the amount owed.
- The section containing the answer to whether an enrollee can leave the M3P program was modified. CMS modified two paragraphs to bullets, though the content is essentially the same.
Below is the revised M3P model document:
Notice of Failure to Pay
When an M3P enrollee fails to make a payment by the due date, the plan sponsor must send the Notice of Failure to Pay. It explains how to make a payment and identifies the grace period. It also explains that CMS may disenroll the participant from the M3P program for failure to pay.
The revised document includes brief instructions for plan sponsors and revised text. Among the revisions:
- The first paragraph includes a reminder of the M3P enrollee’s effective date and a brief program explanation.
- CMS also removed language that indicated that plan sponsors can apply a payment made toward the M3P program to a plan premium instead.
Below is the revised notice.
Notice of Involuntary Termination
The M3P model documents include two related to termination, involuntary and voluntary. Plan sponsors send the Involuntary Termination notice to enrollees if they’ve been disenrolled from the M3P program for failing to make a payment. It indicates how much the terminated participant owes, how to pay their balance, and details other programs that may lower costs.
The revised documents add brief instructions for plan sponsors and include minor text changes throughout.
Below is the revised notice.
Notice of Voluntary Termination
Plan sponsors send the Notice of Voluntary Termination when a member chooses to opt out of the M3P program or if they change their plan. It describes how to re-enroll in the future and additional programs to help lower drug costs.
The revised document adds brief instructions for plan sponsors and includes minor text edits. Among the edits:
- The revised document added optional text to many sections depending on the type of voluntary enrollment that occurred. For example, CMS released new text specifically for those who requested disenrollment versus those who left their plan and disenrolled from the M3P program.
Below is the revised notice.
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