By Trenton Thiede, PharmD, MBA

President at PAAS National®

The CMS-10147 Form, also known as the Medicare Drug Coverage and Your Rights Notice, must be distributed to Medicare Part D beneficiaries when a prescription is not covered at the point-of-sale. This notice informs beneficiaries about their right to contact their Part D plan to request a coverage determination, including an exception. The distribution of the CMS-10147 form is a requirement for all pharmacies, including mail order, specialty and LTC.

While documentation is not required confirming distribution of the CMS-10147, your pharmacy should have a policy and procedure in place addressing how and when the form is being distributed to patients. PBM field auditors have been known to ask questions about your process and may ask to see a copy of the form to ensure you have the most up-to-date version.

On Feb. 11, CMS announced the availability of a renewed Medicare Drug Coverage and Your Rights (CMS-10147) “Pharmacy Notice”. While there were no major changes made to the form, the Office of Management and Budget (OMB) approved a new expiration date of 12/31/2027 for OMB Control #0938-0975.

PAAS Tips:

• Pharmacies can find the updated version of the Medicare Drug Coverage and Your Rights Notice (Form CMS-10147) and instructions, including Spanish, Chinese, Korean, and Vietnamese translations in the “Downloads” section on the CMS website
  
• If the form is integrated into your software system, be sure that your software vendor has uploaded the form with the new expiration date of 12/31/202
  
• Beneficiaries that reside in a long-term care facility are not exempt from receiving the notice; LTC pharmacies should review our guidance in the manual
  
• Look for NCPDP reject code 569 with an explanation of “Provide Notice: Medicare Drug Coverage and Your Rights
  
• The distribution must take place even if the pharmacy obtains a therapeutic alternative. Getting a prior authorization or change to alternative therapy does not waive the notification requirement
  
• Pharmacies should act immediately to implement the updated CMS-10147 form with the 12/31/2027 expiration date. You will not be compliant if this hasn't been done, as the previous expiration date is 2/28/2025.

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