Following recently-announced changes to the Medicare Part D benefit included in the Inflation Reduction Act of 2022, the Centers for Medicare and Medicaid Services (CMS) released additional guidance granting members who use insulin a special enrollment period (SEP).

The SEP begins immediately following the close of AEP and runs through all of next year, from Dec. 8, 2022, through Dec. 31, 2023, and is for any insulin user, regardless of whether the member is new to the plan. Any plan change must be made through 1-800-MEDICARE.

CMS guidance is as follows:

CMS is granting a Special Enrollment Period (SEP) for Exceptional Circumstances to allow beneficiaries to add, drop, or change their Part D coverage if they find a better option after the 2022 Annual Enrollment Period (AEP) and through the end of 2023. This SEP will be available for all beneficiaries who use a covered insulin product and begins on Dec. 8, 2022 and ends on Dec. 31, 2023. Beneficiaries may use this SEP one time during this period. To utilize this SEP, beneficiaries must call 1-800-MEDICARE so a customer service representative can process the enrollment change. Consistent with current policy, when Part D enrollees change plans mid-year, their True Out-of-Pocket (TrOOP) costs carry over from one plan to the next.

AOR Status and Commissions may be Affected by SEP Member Changes
While the specifics of how CMS will process enrollment changes are not known, the SEP may affect commissions for agents of insulin users who change plans. An agent’s agent-of-record (AOR) status will be retained when members make a plan change from any UnitedHealthcare Medicare Advantage (MA), Medicare Advantage Prescription Drug (MAPD), Dual Special Needs Plan (DSNP) or Chronic Special Needs Plan (CSNP) to another UnitedHealthcare MA, MAPD, DSNP or CSNP. Stand-alone Prescription Drug Plans (PDP), Medicare Supplement Insurance and Medicare-Medicaid Plans (MMP) are not included in AOR retention. Specifically:

These scenarios are strictly related to members who use insulin and make a plan change during the SEP thru 1-800-MEDICARE.

For more information, refer to these frequently asked questions (FAQ).

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