CMS / Aetna-Coventry Part D Update

Posted Feb. 4, 2015


NCPA had a call with CMS this afternoon and we have some developments to report.  In summary, CMS conveyed or confirmed the following information:


1)      CMS has issued a Corrective Action Plan (CAP) request to Aetna specifying that Aetna did not meet the Any Willing Pharmacy provisions for 2015 Part D basic plans and  that Aetna must reach out to pharmacies to offer standard terms & conditions to see if they want to participate in any networks they were not included in via the “bid” process from last year.  The CAP includes specific issues that Aetna must address.  CMS has not currently imposed sanctions, only a CAP at this point, but CMS reserved the right to take further action at a later date.

  • CMS verified that the CAP notice specifically addressed Aetna’s need to meet the 2016 Part D Any Willing Pharmacy provisions in the development of their 2016 network(s) and that it would be monitored.
  • CMS verified that Aetna was required via the CAP to provide to pharmacies/PSAO’s a “crosswalk” of their Part D plan benefit packages with reference to which pharmacy network being solicited applied to each plan so that pharmacies could make an informed decision when responding to Aetna’s network solicitations.

2)      The current transition fill period for non-network pharmacies is still set by Aetna to run until at least through February 28. CMS is monitoring the situation and reserves the right to extend this date. 

3)      Coordination of Benefits for Beneficiaries – CMS stated that beneficiaries who were on an Aetna plan but have since moved to another plan should have any monies they paid towards their deductible etc. automatically coordinated with the new plan.  In other words, their out of pocket should carry over to their new plan.


We will provide you with more details as we sort through the Corrective Action Plan document.