M3P Implementation: A Strategic Guide for Timely and Successful Rollout
Posted on August 7, 2024
Plans can achieve a seamless and timely M3P implementation through a strategic approach.
In a recent blog, we outlined the Medicare Prescription Payment Plan (M3P) requirements and their implications for health plans. However, awareness is merely the tip of the iceberg. With M3P’s implementation on January 1, 2025, and member enrollment starting October 15, 2024, health plans must take proactive measures. M3P cannot be properly operationalized without appropriate business, technical, and vendor engagement. A critical step involves defining the technical resources and effort, and determining whether capabilities will be delivered internally or contracted to a partner to provide the necessary technical support. Plans should already be evaluating the work, creating necessary policies, and defining how to execute to get to success. In this blog, we will detail the roadmap for M3P compliance and outline how plans can best prepare to navigate this complex landscape over the upcoming months.
The Foundation of The M3P Compliance Roadmap
An M3P compliance roadmap has three major components:
- A checklist of activities that should already be completed
- A prioritization of initiatives
- A schedule for upcoming milestones
| Activity | |
|---|---|
| What Should Be Complete | – Defining the scope of M3P and identifying the impacted business teams – Defining the technical solution(s) and executing contracts with the selected partner(s) – Understanding and estimating the impact of M3P based on 2023 data to determine how impactful M3P will be for the plan, as every plan will face financial risk – Having a policy outlined for how the plan will manage member billing, reconciliation processes, disenrollment, and collections pursuit |
| What To Prioritize Now | – Requirements gathering – Creating a member opt in/out program through a portal or phone/mail/fax – Tracking program enrollment for eligibility and billing – Coordinating eligibility and balances with the PBM, pull program calculations and transaction history, and generate billing amounts – Developing a system for generating bills, reconciling payments, and generating delinquency letters – Ensuring support for eligibility and MARx file changes – Training and policy development – Preparing a member outreach and communication plan, including plans to promote program awareness and issuance of the election request form in 2024 |
| What To Prepare For Next | – Frequent and thorough testing – Staff training and policy development – Member identification, education, and outreach – Daily, monthly, and quarterly oversight planning |
Challenges of M3P Implementation
With so many moving parts, managing M3P implementation certainly comes with challenges. This initiative is new to the market, and most plans and solution partners are developing their offerings as we speak. Many organizations have not undertaken such an initiative before, so there is no established blueprint to follow. Disruptions and slowdowns are inevitable when navigating this uncharted territory. Plans must adopt an iterative approach, building, testing, fixing, and repeating. In-house solutions require onboarding and training of technical teams within a tight timeframe, as much of this process must be built within the upcoming months, ahead of member enrollment in October.
Another significant challenge is determining where to start. With the combination of payment, enrollment, member experience, and pharmacy into a single new benefit, there is no shortage of starting points for a plan to explore. Our roadmap outlined above should provide insight into some key areas to focus on initially. However, if you have any questions or concerns, please do not hesitate to reach out.
Additionally, the final guidance from the Centers for Medicare & Medicaid Services (CMS) was published on July 16th. This offered clarity on the member identification process, outreach, and educational requirements before the plan year, as well as obligations for Part D plans with $0 dollar cost sharing.
Actions for Plans to Consider
Time is of the essence, and there are several actions health plans can take to ensure they are prepared for M3P. PBMs and other solution providers are responsible for a large portion of the work that needs to be accomplished ahead of October. It is critical for plans to engage with their PBMs and potential solution providers to ensure visibility into a schedule of activities and that the schedule aligns with their own timeline. It is also important to consider the estimated effort required of your business and technical teams to partner and implement services ahead of the deadline. Creating a consistent and transparent line of communication between solution providers and your plan will help smooth the implementation process and ensure fewer issues along the way. Another important aspect of this process is engaging internal teams to educate them on what M3P means and where they need to be involved. This entails discussions with relevant departments to outline their responsibilities and bring everyone together with a cohesive plan for implementation.
As these actions are taking place, we believe in the value of a minimum viable product (MVP) approach to ensure progress. Whether you determine this yourself or leverage an organization like PSG, it is important to define product and business requirements. PSG has deep pharmacy implementation and project management experience and has developed a step-by-step project plan that payers can leverage for the October enrollment and January go-live dates. This guide simplifies the process and helps ensure your organization is meeting deadlines, tracking towards effective dates (October and January), and considering all relevant factors during this process.
Wherever you are in the M3P process, whether just starting or putting the finishing touches on your services, PSG can help. Reach out to our experts to learn more!
