Medicare Part D: CMS's Process and Policy for Enrolling New	 
Dual-Eligible Beneficiaries (21-JUN-07, GAO-07-1022T).		 
                                                                 
Under the Medicare Prescription Drug, Improvement, and		 
Modernization Act of 2003 (MMA), dual-eligible			 
beneficiaries--individuals with both Medicare and Medicaid	 
coverage--have their drug costs covered under Medicare Part D	 
rather than under state Medicaid programs. The MMA requires the  
Centers for Medicare & Medicaid Services (CMS) to enroll these	 
beneficiaries in a Medicare prescription drug plan (PDP) if they 
do not select a plan on their own. CMS enrolled about 5.5 million
dual-eligible beneficiaries in late 2005 and about 634,000 who	 
became dually eligible during 2006. GAO was asked to testify on  
(1) CMS's process for enrolling new dual-eligible beneficiaries  
into PDPs and its effect on access to drugs and (2) how CMS set  
the effective coverage date for certain dual-eligible		 
beneficiaries and its implementation of this policy. This	 
testimony is based on the GAO report, Medicare Part D: Challenges
in Enrolling New Dual-Eligible Beneficiaries (GAO-07-272).	 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-07-1022T					        
    ACCNO:   A71185						        
  TITLE:     Medicare Part D: CMS's Process and Policy for Enrolling  
New Dual-Eligible Beneficiaries 				 
     DATE:   06/21/2007 
  SUBJECT:   Beneficiaries					 
	     Claims processing					 
	     Eligibility determinations 			 
	     Health care programs				 
	     Internal controls					 
	     Medicaid						 
	     Medicare						 
	     Monitoring 					 
	     Pharmaceutical industry				 
	     Prescription drugs 				 
	     Prospective payments				 
	     Reimbursements					 

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GAO-07-1022T

   

     * [1]Background
     * [2]CMS's Enrollment Process Takes Time and Can Create Difficult
     * [3]CMS Made Drug Coverage Retroactive, but Did Not Inform Benef
     * [4]Conclusions
     * [5]Contacts and Acknowledgments

          * [6]Order by Mail or Phone

Testimony

Before the Subcommittee on Health, Committee on Ways and Means, House of
Representatives

United States Government Accountability Office

GAO

For Release on Delivery
Expected at 2:00 p.m. EDT
Thursday, June 21, 2007

MEDICARE PART D

CMS's Process and Policy for Enrolling New Dual-Eligible Beneficiaries

Statement of Kathleen M. King
Director, Health Care

GAO-07-1022T

Mr. Chairman and Members of the Subcommittee:

I am pleased to be here today as you discuss the Medicare Part D
prescription drug benefit. Implementation of this new drug benefit has
raised particular concerns for individuals eligible for both Medicare and
full Medicaid benefits--known as dual-eligible beneficiaries.1 These
individuals account for about 15 percent of all Medicare beneficiaries and
15 percent of all Medicaid enrollees. As a group, they are generally
poorer and tend to have more extensive health care needs than other
Medicare beneficiaries. Under the Medicare Prescription Drug, Improvement,
and Modernization Act of 2003 (MMA),2 dual-eligible beneficiaries--who
previously received drug benefits under Medicaid--have had their
prescription drug costs paid under Medicare Part D since January 1, 2006.
In addition, the MMA requires the Centers for Medicare & Medicaid Services
(CMS)3 to assist dual-eligible beneficiaries by enrolling them in a
private Medicare prescription drug plan (PDP) if they do not select a plan
on their own. CMS enrolled about 5.5 million dual-eligible beneficiaries
in late 2005 for the initial implementation of Part D and about 634,000
beneficiaries who became dual-eligible during 2006.

My testimony today will summarize selected findings from the previously
released GAO report, Medicare Part D: Challenges in Enrolling New
Dual-Eligible Beneficiaries.4 Specifically, my remarks today will focus on
(1) CMS's process for enrolling new dual-eligible beneficiaries into PDPs
and its effect on beneficiary access to drugs and (2) how CMS set the
effective Part D coverage date for certain dual-eligible beneficiaries and
its implementation of this policy.

1We use the term dual-eligible beneficiaries to refer to individuals who
qualify for a state's full package of Medicaid benefits.

2MMA, Pub. L. No. 108-173, tit. I, S 101, et seq., 117 stat. 2066,
2071-2152 (2003) (to be codified at 42 U.S.C. S 1395w-101, et seq. and 42
U.S.C. S 1396u-5).

3CMS is the agency that administers the Medicare program on behalf of the
Secretary of Health and Human Services.

4GAO, Medicare Part D: Challenges in Enrolling New Dual-Eligible
Beneficiaries, [7]GAO-07-272 (Washington, D.C.: May 4, 2007).

To address these issues, we conducted site visits in six
states--California, Maine, Maryland, Michigan, New Jersey, and Texas--to
learn about dual-eligible beneficiaries' enrollment in Part D from the
perspective of state Medicaid agencies, pharmacies, and long-term care
providers. We also interviewed officials from CMS and representatives of
PDPs about issues that pertain to dual-eligible beneficiaries. We
conducted the work for our report from March 2006 through April 2007 in
accordance with generally accepted government auditing standards.

In summary, we found that CMS's process for enrolling new dual-eligible
beneficiaries involves many parties, information systems, and
administrative steps, and takes a minimum of 5 weeks to complete. For the
majority of these individuals--generally Medicare beneficiaries not yet
enrolled in Part D who subsequently qualify for Medicaid--this processing
interval can create difficulties in obtaining Part D-covered drugs at
their pharmacies. For other new dual-eligible beneficiaries--Medicaid
enrollees who become Medicare eligible because of age or disability--CMS
took steps to eliminate the impact of the processing interval by enrolling
them in PDPs just prior to their attaining Medicare eligibility. In
addition, for the Medicare first, Medicaid second group of new
dual-eligible beneficiaries, CMS set the effective date of Part D coverage
to coincide with the first date of their Medicaid eligibility. Under this
policy, which was designed to provide drug coverage for dual-eligible
beneficiaries as soon as they attain dual-eligible status, the start of
their Part D coverage can be retroactively set to several months before
the date of their actual PDP enrollment. We found that CMS did not fully
implement or monitor the impact of this coverage date policy. Although
beneficiaries are entitled to reimbursement for covered drug costs
incurred during this retroactive period, CMS and PDPs did not begin
informing them of this right until March 2007. Also, CMS did not track
Medicare payments made to PDPs to provide retroactive coverage or monitor
PDPs' reimbursements to beneficiaries for that period. We estimate that in
2006, Medicare paid PDPs about $100 million for coverage during periods
for which dual-eligible beneficiaries may not have sought reimbursement
for their drug costs. In the report, we recommend that CMS require PDPs to
notify beneficiaries about their right to reimbursement, monitor
implementation of its retroactive payment policy, and take other steps to
improve the operational efficiency of the program.

Background

Dual-eligible beneficiaries are a particularly vulnerable population.
These individuals are typically poorer, tend to have far more extensive
health care needs, have higher rates of cognitive impairments, and are
more likely to be disabled than other Medicare beneficiaries. About three
out of four dual-eligible beneficiaries live in the community and
typically obtain drugs through retail pharmacies. Other dual-eligible
beneficiaries reside in long-term care facilities and obtain drugs through
pharmacies that specifically serve these facilities.

In general, individuals become dual-eligible beneficiaries in two ways.
One way is when Medicare-eligible individuals subsequently become Medicaid
eligible. This typically occurs when income and resources of beneficiaries
fall below certain levels and they enroll in the Supplemental Security
Income (SSI) program,5 or they incur medical costs that reduce their
income below Medicaid eligibility thresholds. If these Medicare
beneficiaries did not sign up for a Part D plan on their own, they have no
drug coverage until they are enrolled in a PDP by CMS. CMS data show that
this group represented about two-thirds of new dual-eligible beneficiaries
the agency enrolled in PDPs in 2006. According to CMS, it is not possible
for it to predict which Medicare beneficiaries will become Medicaid
eligible in any given month because Medicaid eligibility determinations
are a state function.

Another way individuals become dually eligible is when Medicaid
beneficiaries subsequently become eligible for Medicare by reaching 65
years of age or by completing the 24-month disability waiting period.6
Once they become dual-eligible beneficiaries, they can no longer receive
coverage from state Medicaid agencies for their Part D-covered
prescription drugs. In 2006, this group represented approximately
one-third of the new dual-eligible beneficiaries enrolled in PDPs by CMS.
CMS can generally learn from states when these individuals will become
dually eligible.

5In most states, beneficiaries who qualify for cash assistance from SSI--a
cash assistance program for aged, blind, and disabled individuals with
limited income and resources--automatically qualify for full Medicaid
benefits.

6Under Social Security Disability Insurance (DI), which assists people who
worked but became disabled before their retirement age, individuals are
eligible for Medicare coverage after they have received DI cash benefits
for 24 months.

For dual-eligible beneficiaries, Medicare provides a low-income subsidy
that covers most of their out-of-pocket costs for Part D drug coverage.
This subsidy covers the full amount of the monthly premium that
non-subsidy-eligible beneficiaries normally pay, up to the low-income
benchmark premium.7 The subsidy also covers most or all of a dual-eligible
beneficiary's prescription copayments. In 2007, these beneficiaries are
responsible for copayments that range from $1 to $5.35 per prescription,
depending on their income and asset levels, with the exception of those in
long-term care facilities, who pay no copayments.

CMS's Enrollment Process Takes Time and Can Create Difficulties for Some
Dual-Eligible Beneficiaries

Given the number of entities, information systems, and administrative
steps involved, it takes a minimum of 5 weeks for CMS to identify and
enroll a new dual-eligible beneficiary in a PDP. As a result, two out of
three new dual-eligible beneficiaries--generally those who are Medicare
eligible and then become Medicaid eligible--may experience difficulties
obtaining their prescription drugs under Part D during this interval. For
other new dual-eligible beneficiaries--those switching from Medicaid to
Medicare drug coverage--CMS instituted a prospective enrollment process in
late 2006 that enrolls these individuals before their date of Medicare
eligibility and offers a seamless transition to Part D coverage.

Multiple parties and information systems are involved in identifying and
enrolling dual-eligible beneficiaries in PDPs. As shown in figure 1, CMS,
the Social Security Administration (SSA), state Medicaid agencies, and PDP
sponsors play key roles in providing information needed to ensure that new
dual-eligible beneficiaries are identified and enrolled properly. SSA
maintains information on Medicare eligibility that is used by CMS and some
states. State Medicaid agencies are responsible for forwarding to CMS
lists of beneficiaries whom the state believes to be eligible for both
Medicare and Medicaid. CMS is then responsible for making plan assignments
and processing enrollments. PDP sponsors maintain information systems that
are responsible for exchanging enrollment and billing information with
CMS.

7The low-income benchmark is the average monthly beneficiary premium for
all PDPs in a region, weighted by each plan's enrollment.

Figure 1: Overview of the Major Systems and Steps Used to Enroll
Dual-Eligible Beneficiaries in PDPs

Notes: CMS adapted existing information systems used in the administration
of other parts of the Medicare program to perform specific functions
required under Part D. The Medicare eligibility database serves as a
repository for Medicare beneficiary entitlement, eligibility, and
demographic data. The database is used by CMS to provide up-to-date
information to verify the status of dual-eligible beneficiaries, as well
as determine subsidy status and make assignments to PDPs. The enrollment
transaction system is used to enroll beneficiaries in PDPs. The
eligibility query is used by pharmacies to obtain Part D enrollment
information from the Medicare eligibility database.

The process of enrolling dual-eligible beneficiaries requires several
steps. It begins when state Medicaid agencies identify new dual-eligible
beneficiaries and ends when PDPs make billing information available to
pharmacies and send enrollment information to dual-eligible beneficiaries.
We estimate that it takes at least 5 weeks to complete the process under
current procedures. During this interval, pharmacies may not have
up-to-date PDP enrollment information on new dual-eligible individuals.
This may result in beneficiaries having difficulty obtaining Part
D-covered drugs at their pharmacies. To illustrate why this occurs, we
present the hypothetical example of Mr. Smith, who as a Medicare
beneficiary did not sign up for the Part D drug benefit and, therefore,
upon becoming Medicaid eligible, was enrolled in a PDP by CMS. (Fig. 2
shows the steps in Mr. Smith's enrollment process.)

Figure 2: Mr. Smith, a Hypothetical Example of the Enrollment Process for
a Newly Identified Dual-Eligible Beneficiary Who Was Medicare Eligible but
without Previous Part D Coverage

Notes: The dates presented in this example of enrollment for Mr. Smith
generally represent the best-case scenario. The range of dates represent
the minimum and maximum length of elapsed time allowed for processing and
notification, based on information provided by CMS. GAO makes no
assurances that the events described would occur on the dates provided for
any specific dual-eligible beneficiary.

aThe scenario presented reflects an application to Medicaid based on a
reason other than disability. State Medicaid agencies have 45 days to make
eligibility determinations not based on disability and 90 days for
eligibility determinations based on disability, subject to extensions in
certain circumstances.

bIf the state Medicaid agency did not determine that Mr. Smith was
eligible for Medicaid before it submitted its September dual-eligible
file, his information could not be submitted until October. This scenario
is not presented in this figure.

From the time Mr. Smith applies for his state's Medicaid program on August
11, it takes about 1 month for him to receive notification from the state
that he is eligible for Medicaid, thus beginning the enrollment process.
From there, Mr. Smith's new status is submitted by his state to CMS in a
monthly file transmittal. Once CMS receives the lists of dual-eligible
beneficiaries from all of the states, it verifies eligibility for Medicare
and sets each beneficiary's cost-sharing level. Then, around October 8,
CMS assigns Mr. Smith to a PDP randomly, based on the premium level and
the geographic area served by the PDP.8 CMS next notifies the PDP sponsor,
which then has to enroll him in its plan and assign the necessary billing
information. This billing information, such as a member identification
number, is necessary for pharmacies to correctly bill the PDP for Mr.
Smith's prescriptions. The PDP also has to inform Mr. Smith of his
enrollment information. By the time this process is completed, it is the
middle of October.

CMS has developed some contingency measures to help individuals like Mr.
Smith during the processing interval. However, we found that these
measures have not always worked effectively. For instance, CMS designed an
enrollment contingency option to ensure that dual-eligible beneficiaries
who were not yet enrolled in a PDP could get their medications covered
under Part D, while also providing assurance that the pharmacy would be
reimbursed for those medications. However, representatives of pharmacy
associations we spoke with reported problems with reimbursements after
using this option, which has led some pharmacies to stop using it.

8Some states have assisted dual-eligible beneficiaries by using other
methods to select a PDP for enrollment, including methods that also
consider drug utilization information. For example, the State of Maine
used beneficiary-specific data to reassign nearly half of the state's
dual-eligible beneficiaries to PDPs that covered more of their
prescriptions. After reassignment, the number of beneficiaries whose PDP
covered nearly all of their prescription drugs increased significantly.

To avoid a gap in coverage for beneficiaries transitioning from Medicaid
to Medicare prescription drug coverage, CMS has implemented a prospective
enrollment process. Because states can predict and notify CMS which
Medicaid beneficiaries will become new dual-eligible beneficiaries and
when, CMS begins the enrollment process for these individuals 2 months
before the their anticipated dual-eligible status is attained. By
conducting the processing steps early, the prospective enrollment used for
this group of new dual-eligible beneficiaries should ensure a seamless
transition from Medicaid drug coverage to Medicare Part D coverage. Fully
implemented in November 2006, prospective enrollment applies to about
one-third of the new dual-eligible beneficiaries enrolled in PDPs by CMS.

CMS Made Drug Coverage Retroactive, but Did Not Inform Beneficiaries of Their
Right to Reimbursement

For the majority of new dual-eligible beneficiaries, CMS requires PDPs to
provide drug coverage retroactively, typically by several months. During
2006, Medicare paid PDPs millions of dollars to provide coverage to
dual-eligible beneficiaries for drug costs that may have been incurred
during the retroactive coverage period. However, we found that CMS did not
fully implement or monitor the impact of this policy.

CMS made the effective date of Part D drug coverage for Medicare
beneficiaries who become Medicaid eligible coincide with the effective
date of their Medicaid eligibility. Under this policy, Part D coverage for
these beneficiaries is effective the first day of the month that Medicaid
eligibility is effective, which generally occurs 3 months prior to the
date an individual's Medicaid application was submitted to the state, if
the individual was eligible for Medicaid during this time. Thus, the Part
D coverage period can extend retroactively back several months from when
the actual PDP enrollment takes place.

Medicare makes payments to the PDPs for providing drug coverage
retroactively. Specifically, PDPs are paid approximately $90 per month for
the retroactive coverage period.9 PDPs, in turn, are responsible for
reimbursing their members (or another payer) for Part D drug costs
incurred during the retroactive months. For instance, in the case of Mr.
Smith, while he applied for Medicaid in August and learned of his PDP
assignment for Part D in October, his coverage was effective May 1. If Mr.
Smith incurred any costs for Part D-covered prescription drugs from
May--when he became eligible for Medicaid--through October, he could
submit his receipts to his assigned PDP and be reimbursed by the PDP, less
the copayments he would pay as a dual-eligible beneficiary.

9The $90 per month includes the direct subsidy Medicare pays PDPs for
providing the Medicare drug benefit to any Medicare beneficiary and the
low-income premium subsidy CMS pays PDPs to cover the cost of premiums
dual-eligible beneficiaries would pay if they were not receiving the
low-income subsidy.

We found that CMS's implementation of this policy in 2006 was incomplete.
While dual-eligible beneficiaries were entitled to reimbursement by their
PDPs in 2006, neither CMS nor PDPs notified dual-eligible beneficiaries of
this right. The model letters used until March 2007 to inform
dual-eligible beneficiaries of their PDP enrollment did not include any
language concerning reimbursement of out-of-pocket costs incurred during
retroactive coverage periods. In response to a recommendation in our
report, CMS modified the model letters that the agency and PDPs use to
notify dual-eligible beneficiaries about their PDP enrollment. The revised
letters let beneficiaries know that they may be eligible for reimbursement
of some prescription costs incurred during retroactive coverage periods.

Given the vulnerability of this population, it seems unlikely that many
dual-eligible beneficiaries would have contacted their PDPs for
reimbursement if they were not clearly informed of their right to do so
and given information about how to file for reimbursement, neither would
they likely have retained proof of their drug expenditures. Mr. Smith, for
example, would need receipts for drug purchases made during a 5-month
period preceding the date he was notified of his PDP enrollment--at a time
when he could not foresee the need for doing so.

Further, CMS did not monitor how many months of retroactive coverage PDPs
provided, nor did it monitor PDP reimbursements to beneficiaries for costs
incurred during retroactive coverage periods. Based on data provided by
CMS, we estimate that Medicare paid about $100 million to PDP sponsors in
2006 for retroactive coverage. CMS does not know what portion of this $100
million PDPs paid to dual-eligible beneficiaries to reimburse them for
drug costs. If Mr. Smith's PDP did not reimburse Mr. Smith for any
prescription drugs purchased during the retroactive coverage period, the
PDP retained Medicare's payments for that period.

Conclusions

Given the time it takes to complete the enrollment process, CMS has taken
action to ensure ready access to Part D for some new dual-eligible
beneficiaries, but difficulties remain for others. For the one-third of
new dual-eligible beneficiaries whose eligibility can be predicted, CMS's
decision to implement prospective enrollment should eliminate the coverage
gap in transitioning from Medicaid to Medicare drug coverage. However,
because of inherent processing lags, most new dual-eligible beneficiaries
may continue to experience difficulties obtaining their drugs for at least
5 weeks after being notified of their dual-eligible status. In addition,
CMS's incomplete implementation of its retroactive coverage policy in 2006
means that CMS paid PDPs millions of dollars for coverage during periods
for which dual-eligible beneficiaries may not have sought reimbursement
for their drug costs. Without routine monitoring of this policy, the
agency remains unaware of what portion of these funds was subsequently
reimbursed to beneficiaries and, therefore, cannot ensure the efficient
use of program funds.

Our report contains several recommendations. We recommend that CMS require
PDPs to notify beneficiaries of their right to reimbursement and monitor
implementation of its retroactive payment policy. We also recommend that
CMS take other steps to improve the operational efficiency of the program.
Although the agency did not agree with all of them, it has already taken
steps to implement some of our recommendations. As of March 2007, CMS has
modified its letters to dual-eligible beneficiaries to include language
informing them of their right to reimbursement for drug costs incurred
during retroactive coverage periods and required PDP sponsors to do the
same. In addition, CMS officials told us that they plan to analyze data to
determine the magnitude of payments made to PDPs for retroactive coverage
and the amounts PDPs have paid to beneficiaries. We hope that CMS will use
this information to evaluate the effectiveness of its retroactive coverage
policy. If, after conducting the analysis, CMS determines that it is
paying PDPs substantial amounts of money and dual-eligible beneficiaries
are not requesting reimbursements, the agency may want to rethink its
policy in light of pursuing the most efficient use of Medicare funds.

Mr. Chairman, this concludes my prepared remarks. I would be pleased to
respond to any questions that you or other members of the subcommittee may
have at this time.

Contacts and Acknowledgments

For further information regarding this testimony, please contact Kathleen
King at (202) 512-7114 or [8][email protected] . Contact points for our
Offices of Congressional Relations and Public Affairs may be found on the
last page of this statement. Contributors to this testimony include
Rosamond Katz, Assistant Director; Lori Achman; and Samantha Poppe.

(290647)

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[15]www.gao.gov/cgi-bin/getrpt?GAO-07-1022T .

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Highlights of [16]GAO-07-1022T , a testimony before the Subcommittee on
Health, Committee on Ways and Means, House of Representatives

June 21, 2007

MEDICARE PART D

CMS's Process and Policy for Enrolling New Dual-Eligible Beneficiaries

Under the Medicare Prescription Drug, Improvement, and Modernization Act
of 2003 (MMA), dual-eligible beneficiaries--individuals with both Medicare
and Medicaid coverage--have their drug costs covered under Medicare Part D
rather than under state Medicaid programs. The MMA requires the Centers
for Medicare & Medicaid Services (CMS) to enroll these beneficiaries in a
Medicare prescription drug plan (PDP) if they do not select a plan on
their own. CMS enrolled about 5.5 million dual-eligible beneficiaries in
late 2005 and about 634,000 who became dually eligible during 2006.

GAO was asked to testify on (1) CMS's process for enrolling new
dual-eligible beneficiaries into PDPs and its effect on access to drugs
and (2) how CMS set the effective coverage date for certain dual-eligible
beneficiaries and its implementation of this policy. This testimony is
based on the GAO report, Medicare Part D: Challenges in Enrolling New
Dual-Eligible Beneficiaries (GAO-07-272).

[17]What GAO Recommends

GAO's report contains several recommendations, including that CMS require
PDPs to modify beneficiary notices and that CMS monitor the implementation
of its payment policy. CMS did not agree with all of the recommendations,
but it has taken steps to implement some.

CMS's process for enrolling new dual-eligible beneficiaries who have not
yet signed up for a PDP involves many parties, information systems, and
administrative steps, and takes a minimum of 5 weeks to complete. For
about two-thirds of these individuals--generally Medicare beneficiaries
who subsequently qualify for Medicaid--pharmacies may not have up-to-date
PDP enrollment information needed to bill PDPs appropriately until the
beneficiaries' data are completely processed. As a result, these
beneficiaries may have difficulty obtaining their Part D-covered
prescription drugs during this interval. CMS has created contingency
measures to help individuals obtain their new Medicare benefit, but these
measures have not always worked effectively. For the other one-third of
new dual-eligible beneficiaries--Medicaid enrollees who become
Medicare-eligible because of age or disability--CMS eliminated the impact
of processing time by enrolling them in PDPs just prior to their attaining
Medicare eligibility. This prospective enrollment, implemented in late
2006, offers these dual-eligible beneficiaries a seamless transition to
Medicare Part D coverage.

CMS set the effective Part D coverage date for Medicare eligible
beneficiaries who subsequently become eligible for Medicaid to coincide
with the date their Medicaid coverage becomes effective. Under this
policy, which was designed to provide drug coverage for dual-eligible
beneficiaries as soon as they attain dual-eligible status, the start of
the Part D coverage can extend retroactively for several months before the
date beneficiaries are notified of their PDP enrollment. GAO found that
CMS did not fully implement or monitor the impact of this policy. Although
beneficiaries are entitled to reimbursement for covered drug costs
incurred during this retroactive period, CMS did not begin informing them
of this right until March 2007. Given their vulnerability, it is unlikely
that these beneficiaries would have sought reimbursement or retained proof
of their drug purchases if they were not informed for their right to do
so. Also, CMS made monthly payments to PDPs for providing drug coverage
during retroactive periods, but did not monitor PDPs' reimbursements to
beneficiaries during that period. GAO estimated that in 2006, Medicare
paid PDPs millions of dollars for coverage during periods for which
dual-eligible beneficiaries may not have sought reimbursement for their
drugs.

References

Visible links
7. http://www.gao.gov/cgi-bin/getrpt?GAO-07-272
8. mailto:[email protected]
9. http://www.gao.gov/
  10. http://www.gao.gov/
  11. http://www.gao.gov/fraudnet/fraudnet.htm
  12. mailto:[email protected]
  13. mailto:[email protected]
  14. mailto:[email protected]
  15. http://www.gao.gov/cgi-bin/getrpt?GAO-07-1022T
  16. http://www.gao.gov/cgi-bin/getrpt?GAO-07-1022T
*** End of document. ***