Medicare Part D Opt-In/

Out Deadline Extended Caution: Doctors should make a decision 90 days prior to allow processing, any changes

T

he Centers for Medicare and Medicaid Services (CMS) will be extending to January 1, 2016 the effective date by which dentists must have either enrolled or officially opted out of Medicare in order for prescriptions they write to be covered by Medicare Part D.

This proposed rule also would require Part D plans to cover a “provisional supply” of up to 90 days of a medication prescribed by a doctor who has not enrolled or opted out. A Part D plan must notify the beneficiary in writing within three business days that the medication is being covered on a provisional basis because of the prescriber’s current Medicare status. Part D plans must also make reasonable efforts to notify the prescriber. After covering the provisional supply and providing the notice to the beneficiary, the

Part D plan will be required to reject future claims for the same medication for that ben- eficiary if the prescription is from the same prescriber.

Note that for a dentist to meet the January 1, 2016 effective date, they must submit their application at least 90 days before this date to allow sufficient time for processing.

MEDICARE ADVANTAGE (MA) PLANS

“Opting out” is not an option for any provid- er who treats patients in a Medicare Advan- tage (MA) plan and wishes for their patients to receive the benefit from the MA plan. This is true whether the provider is in-network for the MA plan or not (for PPO-type MA plans). The MA organization is required to check the opt out list on a regular basis.

Remember, if a dentist already has opted out, they can revert their decision within 90 days. Enrolling either using the 855I (full enrollment) or the 855O (ordering and refer- ring provider) are valid options for a dentist treating patients with an MA plan. If a non- contracted dentist enrolls in Medicare using the 855I, this does not mean the dentist is now an MA plan participant, i.e. in-network for the MA plan.

MEDICARE RESOURCES AT ADA.ORG

The video the ADA has on its Center for Pro- fessional Success (CPS) website continues to be the most accurate information they have on this topic (other than the change in date noted above) http://success.ada.org/en/prac- tice/medicare/medicare/medicare-overview- video-tutorial. Please direct any questions to the ADA at dentalbenefits@ada.org.

Aetna Medicare Advantage Organization Plan Letter to Dentists S

everal dentists have contacted the MDA in regard to a letter

from Aetna that implied that as a current participating Aetna provider they were automatically enrolled into a Medicare Advantage Orga- nization (MAO) plan. It stated that some of the provider’s patients may be members who get their dental coverage as an optional supplemen- tal benefit to an Aetna Medicare Advantage medical plan.

Dentists were immediately con- cerned about being placed into these plans without their knowl- edge, what the fee schedule would entail, what this meant in terms of paper work and/or the training program requirements for Medicare Advantage Programs, etc.

16 focus | MAY/JUN 2015 | ISSUE 3

The ADA has been addressing this matter with Aetna to give the MDA guidance, including the following information:  All dentists who have a provider contract with Aetna got the “contract amendment” letter.

 In signing the base contract, dentists participating with Aetna have already signed up for ALL of Aetna’s plans;

 However, if you do not want to be considered an in-net- work participating provider for Aetna’s Medicare Advantage Organization (MAO) plan we recommend you contact your provider representative and clarify your options for con-

tinuing/discontinuing to serve as a participating provider for Aetna’s MAO network.

Irrespective of whether you are a participating provider with Aetna’s MAO plan, you need to make a decision on the Medicare Part D regulation. If you treat Medicare advantage patients (irrespective of whether you are in or out of the network) AND would like your patient to receive the benefit for dental services, “opting” out is not an option for you. Dentists who have already opted out have 90 days to change their minds. The ADA continues to address MDA’s other concerns on this regulation with CMS.

It also is important to note that the opt in/opt out enrollment for dentists has been extended until January 1, 2016. But, make sure to not wait until January 1 because processing your application may take up to 90 days, and you want to be able to make possible changes within that 90 day timeframe. The MDA will keep members updated on any additional information we receive. We also encourage you to keep updated through ADA notifications and by viewing the extensive information on the ADA website that has been gathered to assist dentists with their decision making at http://success.ada.org/ en/practice/medicare.