On January 27, 2025, AVAC submitted comments on the proposed rule, “Medicare and Medicaid Programs: Contract Year 2026 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicare Cost Plan Program, and Programs of All-Inclusive Care for the Elderly.”
Specifically:
- Support codifying that any ACIP-recommended adult vaccine is exempted from all beneficiary cost sharing for Calendar Year (CY)2026 and beyond.
- Support codifying the definition of an “ACIP-recommended adult vaccine.”
Appreciate the proposal to enable enrollees who submit direct member reimbursement (DMR) requests for ACIP-recommended adult vaccines accessed at either out-of-network pharmacies or providers, or at in-network pharmacies or providers to receive the benefit with no added cost sharing. - Encourage Part D and Medicare Advantage plans to avoid utilization management strategies that hinder a provider or pharmacy’s ability to choose to stock and offer vaccines to Part D beneficiaries.
- Appreciate the proposal clarifying that Part D plans must provide coverage without cost sharing once a new or revised recommendation is adopted by the CDC Director and posted on the CDC website.