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CVS Offering Point-Of-Sale Rebates In Part D Next Year With SilverScript Plan

Executive Summary

Premiums will average about $80 for enhanced plan, well above average $32.50 premium for basic stand-alone Medicare Part D coverage in 2019.

CVS Health Corp. is bringing point-of-sale rebates to the Medicare Part D market with a new stand-alone plan offered under its market-leading SilverScript insurance brand for 2019.

SilverScript Allure is one of three plans being introduced by the sponsor for next year. It offers lower out-of-pocket costs on branded drugs at both retail and mail by passing along a portion of negotiated rebates at the point-of-sale.

The fact that POS rebates are moving into the Part D market is notable and beneficiary sign-ups in the Allure plan will be worth watching. Open enrollment for Part D begins Oct. 15 and runs through Dec. 7.

The Centers for Medicare and Medicaid Services in late 2017 solicited public input on whether and how to require POS rebates in Part D as a way of lowering drug costs. But the agency has not yet moved ahead with any regulations. Critics of the policy argue it would drive up premiums. (Also see "Big Brand Price Reductions Would Be Needed Without Rebates In Part D, Humana Warns " - Pink Sheet, 25 Jul, 2018.)

National insurers [UnitedHealthCare] and Aetna Inc. have introduced POS rebates in their commercial businesses but have not announced plans to do so in Medicare. (Also see "UnitedHealthcare Will Apply About 80% Of Rebates At Point-Of-Sale" - Pink Sheet, 26 Apr, 2018.) CVS says it pioneered the introduction of POS rebates to commercial payers in 2013 and nearly 10m members currently benefit from them.

In the SilverScript Allure plan, rebates will be shared on those drugs covered in the higher formulary cost-sharing tiers (tiers, 3, 4 and 5), which are typically brands, including non-preferred products, and specialty drugs. The portion of rebate that is passed along will vary by drug class, according to CVS. However, the company is not disclosing the specific amounts it will redirect.

Beneficiaries will be able to find drug cost information on the SilverScript website and via the “Full Cost of Drug” fields on the Medicare.gov Plan Finder, which will be updated with the estimated member’s cost-share, including POS rebates, for specific branded drugs, the CVS spokesperson explained.

Alluring At $80 Per Month?

Premiums for the Allure plan will average $80 per month but will vary across regions. That’s well above the average premium for basic stand-alone Part D plans, which is $32.50 for 2019, according to the Centers for Medicare and Medicaid Services.

However, Allure is an enhanced plan that, in addition to POS rebates, offers a $0 deductible on all covered drugs and $0 copays for 90-supplies of tier 1 (usually generic) drugs when filled through the CVS Caremark Mail Service Pharmacy, or copays as low as $1 on a 30-day supply of a tier 1 drug when filled at a preferred retail pharmacy.

Allure's premium is “slightly” above the average premium of the other SilverScript enhanced plan being offered for 2019, a CVS spokesperson pointed out. SilverScript Plus is designed for beneficiaries that take several medications on a regular basis and are likely to reach the coverage gap in 2019.

It offers $0 copays for 90-day supplies of tier 1 and 2 drugs nationwide through mail order in both the initial coverage phase of the Part D benefit and through the coverage gap. It also offers $0 deductible on all covered drug and discounts on drugs obtained through preferred pharmacies.

SilverScript Choice is the third plan being offered for 2019 and includes the most basic coverage.  It does not require a deductible amount and provides $0 copays for 90-day supplies of tier 1 drugs when filled through mail order. SilverScript Choice and Plus plans are also available in 2018 and the Choice plan is the most popular in terms of enrollment.

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