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US · guidance

CMS Pub. 100-18, ch. 6, App. E

Appendix E: Sample Transition Supply Scenarios and Eligibility

activein force · 2026-09-17 – presentas-observed

A Part D sponsor must provide for an appropriate transition process for certain enrollees who

are prescribed Part D drugs that are non-formulary in order to promote continuity of care and

avoid interruptions in drug therapy while a switch to a therapeutically equivalent medication or

the completion of an exception request to maintain coverage of an existing drug based on

medical necessity reasons can be effectuated. See Sections 30.4 – 30.4.11 for additional

guidance.

Coverage Year 1 Coverage Year 2 Transition Eligible?

Sponsor A

Plan ABC (on formulary)

Sponsor A

Plan ABC (on formulary)

No

No change in formulary

Sponsor A

Plan ABC (non-formulary and/or new

UM criteria)

Yes

Negative change; potential

interruption of coverage

Sponsor A

Plan EFG (on formulary)

No

No change in formulary

Sponsor A

Plan EFG (non-formulary and/or UM

criteria)

Yes

Non-formulary change; potential

interruption of coverage

Sponsor B

Plan JKL (on formulary)

No

No interruption of coverage

Sponsor B

Plan JKL (non-formulary and/or UM

criteria)

Yes

Non-formulary change; potential

interruption of coverage

Sponsor A

Plan DEF (non-formulary)

[filled under exception]

Any Sponsor

Any Plan (on formulary)

No

No interruption of coverage

Sponsor A

Plan DEF (non-formulary)

Yes

Plans may approve an exception

or transition to a formulary item

prior to the new contract year

Sponsor A

Plan DEF (on formulary, with UM

criteria)

Yes

Plans may approve an exception

or transition to a formulary item

prior to the new contract year

Sponsor B

Plan MNO (non-formulary and/or UM

criteria)

Yes

Potential interruption of coverage

History

(Rev. 18, Issued: 01-15-16, Effective: 01-15-16; Implementation: 01-15-16)

Provenance

Source
cms.gov
Retrieved
2026-09-17
Edition
iom-2026-09-17
Content hash
d5d430852c368d11cf223be4dd308881ac367816f8d17fae2f5fcd16435120e1
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