Transition Policy 2026 Medicare
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Governs the Company's transition procedures to provide temporary access to Part D drugs when an enrollee presents with a non-formulary medication or one subject to prior authorization, step therapy, or quantity limits; applies to new enrollees, transfers, LTC residents, and enrollees affected by formulary changes.
No material clinical or coverage changes in this revision.
Transition Coverage Criteria
inv-01: Transition coverage criteria
Temporary transition supplies are provided and exceptions/prior authorization (PA) are evaluated based on documented medical necessity; retail and long-term care (LTC) provisions apply.
inv-02: Transition coverage and operational criteria
Operational rules for temporary fills, cost-sharing, allowed overrides, protected-class handling, and identification of ongoing therapy during transition.
inv-03: Transition coverage criteria
Options and requirements for handling transitions across contract years, sponsor responsibilities, and system/administrative provisions for extended or alternate supplies.
Sponsor options
- Option 1: Sponsor provides transition at the start of the new contract year consistent with new enrollee process—temporary supply and notice that enrollee must switch to formulary or request an exception.
- Option 2: Sponsor effectuates transition prior to January 1 by prospectively transitioning enrollees and/or completing exception requests before Jan 1; if exception granted, authorize payment prior to Jan 1; if not transitioned, provide transition supply beginning Jan 1.
Coding and System Indicators
| Prior Authorization, Step Therapy Transition Codes | Two-letter codes used to specify the type of transition fill. |
| NCPDP messaging codes | NCPDP-approved message codes and free text messages returned to pharmacy identifying transition fills and reasons. |
Provider Actions and Operational Steps
Medical review and actions when transition claims pay
The Company conducts medical review and coverage determinations for prior authorization (PA), step therapy (ST), quantity limit (QL) and non‑formulary drug requests; when a transition claim pays the plan provides a transition letter to member and prescriber, allows the prescriber to suggest formulary alternatives, and enables initiation of PA/exception requests as needed. Members are notified of appeal/redetermination rights when denials occur and appeals/redeterminations are available if a PA or exception is denied.
- Provide transition letter to member and prescriber when transition claim pays.
- Prescriber may suggest/formulary alternatives or initiate PA/exception if no appropriate alternative.
- Appeals/redetermination available and expedited on request when denials occur.
Point-of-sale UM edits and adjudication during transition
At point-of-sale the Company resolves step therapy and prior authorization edits by allowing paid transition claims and applies only limited UM edits during transition: Part A/B vs Part D determinations, prevention of coverage for non‑Part D drugs, and edits to promote safe utilization.
- Step therapy and prior authorization edits are resolved at POS through paid transition claims.
- Applied POS UM edits: Part A vs B/D determinations, non‑Part D prevention, and safe utilization edits.
One-time authorizations for level-of-care changes
When a level-of-care change is not automatically identified, the pharmacist must call the Pharmacy Help Desk to notify them so a one-time authorization can be entered to allow the claim to pay; these are entered as one-time authorizations and additional one-time authorizations are placed for subsequent level-of-care changes.
- Pharmacist calls Pharmacy Help Desk to report level‑of‑care change if system did not auto-identify.
- Help Desk places a one-time authorization to allow the claim to pay.
- Enter additional one-time authorizations for subsequent level‑of‑care changes to prevent therapy gaps.
Overrides at POS and beneficiary exception/appeal rights
If UM edits are overridden at point‑of‑service solely for transition fills, the beneficiary is notified and may begin the formulary exception process; all non‑formulary, PA, ST, or QL edits remain subject to exception and appeal procedures.
- Overrides at POS for transition-only fills trigger beneficiary notification (transition letter).
- Beneficiary may initiate an exception request and pursue appeals/redeterminations if needed.
- Non‑formulary, PA, ST, and QL edits remain subject to exception and appeal even when waived for transition.
Availability and submission methods for PA/exception requests
Prior authorization and formulary exception request forms are available upon request to enrollees and prescribers via mail, fax, email, and plan sponsor websites; requests may be initiated by the beneficiary, authorized representative, prescriber, or pharmacy and submitted in writing, by phone, email, or fax.
- PA/exception forms provided for convenience via mail, fax, email, and plan websites.
- Requests may be submitted by beneficiary, authorized representative, prescriber, or pharmacy.
- Submission methods include written, telephonic, email, or fax.
Case‑by‑case extension of transition period when appeals/requests pending
The Company will extend the transition period on a case‑by‑case basis when an exception request or appeal has not been processed by the end of the minimum transition period; extensions must be initiated by the beneficiary, authorized representative, prescriber, or pharmacy and may be requested in writing, by phone, email, or fax.
- Extensions provided until a transition is made or a decision on the exception request is issued.
- Initiation permitted by beneficiary, authorized representative, prescriber, or pharmacy.
- Requests accepted in writing, telephonically, by email, or by fax.
Attachments
Attachments: None. There are no attachments associated with this policy.
Key Terms and Definitions
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