Coverage Determinations, Exceptions, and Appeals
If your new pharmacy tells you that a medication is not covered by your plan, or your plan requires a higher co-payment for your medication than for other similar medications, you have the right to have that decision reviewed and possibly changed. This decision process is known as the exception and appeals process. If you decide to file an exception to get your medication covered by your Medicare prescription drug plan, be sure to keep track of all contacts you make (name of the person, phone number, and date and time of the call).
Questions Answered
What are coverage determinations, exceptions, and appeals?
A coverage determination is a written letter from your plan telling you that it will not cover a drug.
An exception is a formal decision by your plan to cover your medication or reduce your co-payment. If an exception is granted, it will for last one year from the date of the decision and will then need to be requested again.
If the plan does not grant the exception, you may take your case to another decision maker. This is known as an appeal.
How do I know if I should file for an exception and/or appeal?
Check Your Plan
Call your plan hotline to find out if your medication is or is not covered. You can find your plan’s phone number either in your plan enrollment materials or on your Medicare prescription drug card. If your medication is not covered, ask for a one-time supply of your medication(s) to help you while you request an exception. Plans approved by CMS will offer at least a 30-day supply called a “transition supply” or “emergency supply.” Your plan should then send you a coverage determination in writing.
Tell Your Doctor or Case Manager
Call your doctor’s office or your case manager to tell them of the denial. They need to be prepared to help you.
Think About Your Options
You should talk with your doctor to either switch your medication to one that is covered by your plan or to request that the plan cover your medication (called an exception). If you have both Medicare and Medicaid, you may also want to look at other plans offered in your area to see if a different plan better meets your needs.
Ask for an Exception
Ask your doctor or a family member to help you ask for an exception. Your doctor will have to show why this medication is needed (called “medical necessity”) for your plan to grant your request. See your Medicare prescription drug plan documents for forms and phone numbers that you might need for this process. Save copies of these forms with times and dates, and give a copy to your doctor or case manager for your file.
After your plan receives your request and supporting statement from your doctor, the plan must make a decision about your request within 72 hours (or 24 hours in an emergency). If you get an exception, go to the pharmacy to have your prescription filled. The exception will last for one year from the date it is approved. If your exception request is denied, you can appeal.
How many steps will I have to go through during the appeals process?
There are five levels of the appeal process. The details of each level are provided below.
Appeal #1: Ask for Redetermination
Ask your Medicare prescription drug plan to review your request to get your medication again (called a redetermination). Your plan materials will tell you if this can be done either in writing or over the phone and what kind of information they need from you or your doctor to make a decision.
Your Medicare prescription drug plan must notify you of a decision within seven calendar days (or 72 hours in an emergency) from the time it receives all your information. If you get a redetermination in your favor, fill your prescription. It will last for one year from the date of the plan’s decision. If your redetermination is denied or the plan does not respond by the deadline, file for appeal #2, also known as reconsideration.
Appeal #2: Ask for Reconsideration
At this level, you will ask an Independent Review Entity (IRE) to review your plan’s previous decision. An IRE is a regional organization under contract with prescription drug plans to review their decisions and make sure that the plans have followed processes and reviewed the details of your request properly. Your request to the IRE may be filed either in writing or over the phone.
- The IRE must get your doctor’s views in writing, on the phone, or at a teleconference.
- If your plan does not meet the deadlines for making a decision on your exception or redetermination request, the plan must automatically forward your request to the IRE within 24 hours.
- The IRE must let you know of their decision within seven calendar days (or 72 hours in an emergency).
If the IRE decides in your favor, go to the pharmacy and fill your prescription. The decision to cover your medication will last for one year from the date of the decision. If the reconsideration is denied, you may file appeal #3 – a request for an administrative law hearing.
Important Note: If your requests for your plan to cover a medication have been denied through the first two reviews, you should talk to your doctor before making another request (going to appeal levels #3-5). The time to get a decision on further appeal requests is much longer and plans are not required to give you refills of your medication during these later levels of appeals. Talk with your doctor about other medications that might work for you, or find other ways to get your medication, such as charitable organizations, drug manufacturer programs, or state-funded programs. The Partnership for Prescription Assistance can help you find programs to help you (www.pparx.org or 1-888-477-2669).
Appeal #3: Ask for an Administrative Law Judge (ALJ) Hearing
If the IRE denies your reconsideration request, you may ask for review by an Administrative Law Judge (ALJ), a federal government employee who will review your case to make sure the plan has followed proper processes and has reviewed your case in a way that meets federal legal requirements. A lawyer may help you with this review. To receive a hearing, your medication costs must be at least $100 (including all refills). This amount will increase yearly.
An ALJ has 90 calendar days to grant a hearing request and 90 calendar days to make a decision. If the ALJ decides in your favor, fill your prescription at your network pharmacy. The decision to cover your medication will last one year from the date of this decision. If your request is denied, then go to appeal #4 – the Medicare Appeals Council.
Appeal #4: Ask for Review by the Medicare Appeals Council
If the ALJ does not approve your request, you may file an appeal with the Medicare Appeals Council, part of the Centers for Medicare and Medicaid Services (CMS). You may have legal help with this review.
The Medicare Appeals Council has 90 calendar days to decide a case. If the Medicare Appeals Council decides in your favor, fill your prescription. It will last one year. If not, go to the final level of appeal – federal court.
Appeal #5: Ask for Review by Federal Court
If the Medicare Appeals Council denies your request, you may appeal to federal court. This step is also known as “Judicial Review.” A lawyer may help you. To appeal at this stage, your total costs must be at least $1,050 in 2006 (This amount will increase yearly).
If all your appeals are denied, you should:
- Contact your doctor or case manager to talk about other medication options.
- Contact the Partnership for Prescription Assistance or your local State Health Insurance Assistance Programs (SHIP). There may be a program to help you pay for your drugs. See the Additonal Resources section for contact information.
Is there legal help available for the appeals process?
You are able to get legal help with the hearing process during appeal levels 3-5. To find legal help in your area, use the resources listed below. Look for legal aid organizations, health disability law organizations, or law firms that focus on Medicare:
- The American Bar Association website for free legal services.
- If you are over 60 years old, you may find legal help here.
Current as of 9-26-2005
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