CMS Pub. 100-18, ch. 7, § 30.7

During the MTMP approval process, CMS reviews the MTMP submission to ensure Part D

sponsors meet the following expectations:

• Beneficiaries will not be disenrolled from the MTMP program if they no longer meet one

or more of the MTMP eligibility criteria as defined above, and will remain in the MTMP

program for the remainder of the calendar year;

• The MTMP will serve and provide interventions for enrollees who meet all three of the

required criteria, as defined above, regardless of setting (e.g., ambulatory, long term care,

etc.);

• The MTMP will not include discriminatory exclusion criteria. If an enrollee meets all

three of the required criteria as described by the plan, the enrollee should be eligible for

MTM intervention;

• The plan will put into place safeguards against discrimination based on the nature of its

MTM interventions (i.e., TTY if phone-based, Braille if mail-based, etc.).

• The plan will consider the provision of the other prescription drug quality improvement

interventions to beneficiaries who do not meet all three of the required MTMP criteria as

described by the plan, however, these cannot be considered for MTM reimbursement by

CMS.

• Plans will promote continuity of care by performing an end-of-year analysis that

identifies current MTM program participants who will continue to meet the eligibility

criteria for the next program year for the same plan.

• Plans will have procedures in place to drive participation and follow-up with

beneficiaries that do not respond to initial offers for MTM services.

• Plans will consider using more than one approach when possible to reach all eligible

patients who may wish to receive MTM services.

• Plans will analyze and evaluate their MTMP and make changes to continuously improve

their programs.

An MTMP is based on the contract year. The plan's bid should take into account MTM costs for

the applicable contract year, as MTMPs can change from year to year. As mentioned above, it is

CMS’ expectation that once enrolled in the MTMP, beneficiaries will not be disenrolled if they

no longer meet one or more of the MTMP eligibility criteria as defined by the plan and will

remain enrolled in the MTMP program for the remainder of the calendar/contract year. This

expectation, however, would not apply across contract years.