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Annual Transition Policy and Attestation Submission to CMS

By February 9, 2022March 7th, 2022CMS, HPMS, Part D

The Centers for Medicare and Medicaid Services (CMS) requires, as part of the formulary submission process, each plan sponsor  complete the Transition Policy Attestation through the formulary submission module in the Health Plan Management System (HPMS). Plan sponsors must also provide the Transition Policy via upload into HPMS by June 6, 2022

CMS releases the transition policy attestation via HPMS each year in mid-May. Plan sponsors must attest ‘Yes’ to each of the qualifications, regarding a transition process for members, as listed in the attestation in order to be approved or renewed for a Part D contract.

In addition to the attestation, an ‘Implementation Statement’ needs to be contained within the submitted transition policy that provides a detailed explanation of how Part D sponsors process transition requests within their adjudication system and needs to include:

  • How the pharmacy is notified when a transition medication is processed at the point of sale
  • Description of edits
  • Explanation of the process pharmacies follow to resolve transition medication edits at the point of sale

CMS, or its delegated parties, will review the submitted information and will provide comments to the sponsor if there are any questions or if additional information is needed.  Plan sponsors should send updates only if requested by CMS and should only respond to the specific comments and questions received from CMS.  CMS will include any due date for the additional information with the inquiry. If a sponsor does not receive any comments or feedback from CMS or its delegate, no additional steps are required.  In the past, these inquires with questions or requests for additional information have been received by plan sponsors in the later part of July after the early June initial submission.

Suggested Best Practice Tips:

  • Assign a delegated owner  to be watchful for the attestation release in HPMS and take note of the required due date for uploading into HPMS.
  • Review your current year’s Transition Policy and identify any possible changes for the new year and ensure any changes made to the claims adjudication system are reflected in the new year policy. This review can begin prior to the attestation release.
  • Ensure that each Attestation is addressed in the transition policy and addressed in a manner that is easy for CMS to identify
  • Coordinate  all plan sponsor required reviews and approvals of the attestation, policy and implementation statement to ensure the CMS due date is met.
  • Proofread your final version before submission and ensure all comments and extraneous markings have been deleted.
  • Upload the documents into the formulary submission module in HPMS by or before the CMS due date.
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