Lexology April 23, 2024
On April 4, the Centers for Medicare & Medicaid Services (CMS) released the Contract Year (CY) 2025 Medicare Advantage (MA) and Medicare Part D Policy and Technical Changes final rule (“Final Rule”), which included revisions to the regulations governing how MA organizations and Part D plan sponsors (referred to collectively throughout as “issuers”) compensate agents, brokers and third parties. In this rulemaking, CMS raised a number of concerns about third party marketing organizations (TPMOs) and, specifically, field marketing organizations (FMOs) having undue influence over beneficiary plan selection and competition among issuers. Despite some speculation that CMS would force an overhaul of issuers’ contractual relationships with TPMOs, the Final Rule should only affect contract provisions that could interfere with agent and...
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