A troubled beginning for Part D: behavioral health providers detail how they've been trying to help patients access the new drug benefit.
"From its inception, Part D has been an utter hassle for mental health service providers," says Jim Van Norman, MD, medical director of the Austin Travis County MHMR Center in Texas. When the program first began, he notes, more than 6.2 million dually eligible Medicare and Medicaid recipients automatically were enrolled in Part D plans. Yet "it was difficult to figure out which plan the dual eligible was randomly enrolled in and whether that plan was the best option for the patient," he explains. In addition, since many dually eligible beneficiaries have cognitive impairments, they were particularly vulnerable during the transition period because drug regimen consistency is paramount for patients with behavioral issues.
But for behavioral health agencies and their patients, the problems didn't end there. "Looking at the formulary choices available, it's clear that certain medications for patients with mental illness aren't covered," Dr. Van Norman adds. Two classes of drugs prescribed by behavioral health providers--benzodiazepines and barbiturates--are excluded from coverage, but Part D plans are required to cover all antipsychotic, anticonvulsant, and antidepressant drugs, according to Andrew Sperling, legislative director of the National Alliance on Mental Illness (NAMI).
Under Part D, mental health treatment caregivers also are hindered because patients aren't always able to receive higher doses of medications than those specifically authorized under the program, according to Dr. Van Norman. "Sometimes," he explains, "it's necessary to push doses higher than what's listed by the FDA to get a full response." But the managed care companies that administer the plans aren't always flexible in approving higher doses, he adds.
In fact, Dr. Van Norman recently spent 40 minutes on the phone and three days completing paperwork to gain authorization to treat a patient with a higher dose than permitted by the plan administrator. "Meanwhile, the patient was getting frantic," he says.
Another big Part D issue for behavioral health providers: Most states are not offering additional financial assistance or wraparound coverage to help dual eligibles with their copayments, according to a recent survey by the American Psychiatric Association. And when such coverage is available, it can be hindered by budgetary constraints. For example, in New York the proposal at press time limited wraparound help beginning July 1 to atypical antipsychotics, antidepressants, retroviral medications used in HIV/AIDS, and antirejection drugs used in organ and tissue transplants. Those with comorbidities may find that one or more of their non-mental health-related medications will not be covered by the supplemental wraparound program, explains Phillip Saperia, executive director of the Coalition of Voluntary Mental Health Agencies (CVMHA) in New York City.
In New York State, notes Karyn Krampitz, who operates a provider help line for the coalition, the legislature did approve an emergency Medicaid safety net program in February, which allows dual eligibles to get their medications paid by Medicaid if their first request for an exception is denied by the Medicare Part D drug plan. But that program will expire when the New York State health commissioner determines that the problems with Part D implementation are over. Krampitz is concerned that the safety net program is diverting attention from other troubling issues, such as drugs not being included in plan coverage and prior approval requirements. "Once the safety net is gone," she explains, "we're afraid we'll be back to square one: beneficiaries without immediate access to their medications."
For Linda Rosenberg, president and CEO of the National Council for Community Behavioral Healthcare, a critical component of the Part D problem is that Congress mandated a society-supported benefit for seniors while also trying to trumpet private business. "Promoting private business is certainly a good thing, but not necessarily when it comes at the expense of good public policy," says Rosenberg. Therefore, the National Council would like to see the law changed to eliminate copayments for the poorest of the poor. "Two or three dollars doesn't sound like a lot of money, but for people on limited incomes, it can be," she notes.
Medicare doesn't come close to paying for all drug expenses. Once a senior pays the deductible (in addition to a monthly premium), Medicare will cover only 75% of prescription drug costs until $2,250 in bills have been accumulated. At that point, beneficiaries are responsible for the entire costs of their medications until total drug expenses reach $5,100, when Medicare will cover 95% of the costs. That gap in coverage, called the "doughnut hole," was implemented to save the government money, but the doughnut hole does not apply to dual eligibles.
Even with the doughnut hole, however, the government is expected to pay more than $720 billion for Part D over the next decade, according to officials at the Centers for Medicare and Medicaid Services (CMS).
To cope with these Part D issues, many mental health centers have increased their staff level to help match clients with the most appropriate plans and deal with plan-related problems, says Rosenberg. In fact, the National Council is seeking additional reimbursement from Medicare for the unanticipated expenses incurred by its members in educating and advising their clients.
When it comes to the Part D bureaucratic maze, Cindy Ostrowski, program director at the St. Luke's House, a community-based psychiatric rehabilitation program in Bethesda, Maryland, says pharmacists did not always receive accurate information about how the Part D software program operates. In some cases, that resulted in dual eligibles not getting their prescriptions filled because pharmacies weren't able to verify their eligibility or placement in a plan. In other situations, dual eligibles were expected to pony up significant copayments--even after CMS had provided for 14-day emergency supplies to be doled out--according to Ostrowski. "I'm not casting aspersions. The pharmacists have been in a very difficult position. They just weren't aware of all the rules and resources," she says.
In addition, Ostrowski points out, when patients did join one of almost four dozen plans in Maryland, they often did not receive their identification cards needed to get prescriptions filled until mid-February. To remedy this and other problems, St. Luke's House trained its staff to accompany clients at pharmacies to help them navigate Part D's complexities. Although the Community Behavioral Health Association of Maryland conducted training five or six months ahead of time to hit the ground running, the start-up did not go smoothly, according to Ostrowski. "We had people who are living on little income rationing their medications, only taking them on certain days, or who were hoarding their medications," she reports.
But it's not all doom and gloom on Part D, say some behavioral health professionals. While agreeing that there have been significant problems with the program, NAMI's Sperling says the glitches are being remedied. Placing dual eligibles in programs through automatic enrollment actually was a good idea because it makes sure they are enrolled in the program, and they can always switch plans if they want, he says. However, Sperling notes, when dually eligible beneficiaries switched plans in late December, computer problems prevented pharmacies from verifying eligibility. And that resulted in dually eligible beneficiaries being charged large copayments, instead of the usual $1 for generic and $3 for brand-name prescriptions. Since then the computers have been brought up to speed, additional personnel have been trained, and special help-line staff have been verifying eligibility, he reports.
Nevertheless, NAMI is backing congressional measures that would require Medicare drug plans to waive cost sharing for dual eligibles and remove the benzodiazepine exemption. And the group also has put out a tip sheet for consumers explaining cost-sharing requirements and how to get authorization for a drug not on a plan's preferred drug list (available at www.nami.org).
For CVMHA's Saperia, however, the real issue is that the program remains too complicated and bureaucratic: "Most of the Medicare Part D population just doesn't have the skills to navigate this process."
Michael Levin-Epstein is a freelance writer. To send comments to the author and editors, e-mail firstname.lastname@example.org.
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|Date:||Apr 1, 2006|
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