SCPC Applauds New CMS Part D Plan Guidance as Win for Nursing Home Patients, Front-Line Long-Term Care (LTC) Pharmacies Who Serve Them

DATE: April 23, 2020

New Guidance on “Prior Authorization” and “Short Cycle Dispensing” Cited

Washington, DC – Calling newly-revised Centers for Medicare and Medicaid Services (CMS) guidance to Medicare Part D Plans (PDP) a victory for vulnerable seniors in nursing homes and the front-line long-term care (LTC) pharmacies who serve them, the Senior Care Pharmacy Coalition (SCPC) today applauded CMS for acting upon its request for specific administrative relief on several key fronts.

“As our nation continues to battle the COVID-19 pandemic, SCPC thanks CMS for its revised guidance to PDPs relaxing requirements concerning ‘prior authorization’ and ‘short cycle dispensing’ in a manner beneficial to vulnerable nursing home patients and the dedicated front-line LTC pharmacies who serve them,” stated Alan G. Rosenbloom, President and CEO of SCPC.

Regarding Prior Authorization, CMS clarifies that the agency is relaxing requirements and encourages PDPs to do the same:

As is the case for Medicare Advantage Organizations, consistent with flexibilities available to Part D Sponsors absent a disaster or emergency, Part D Sponsors may choose to waive prior authorization requirements at any time that they otherwise would apply to Part D drugs used to treat or prevent COVID-19, if or when such drugs are identified. Sponsors can also choose to waive or relax PA requirements at any time for other formulary drugs in order to facilitate access with less burden on beneficiaries, plans, and providers. Any such waiver must be uniformly provided to similarly situated enrollees who are affected by the disaster or emergency. We encourage plans to consider utilizing this flexibility.

Regarding Short Cycle Dispensing CMS has exercised its enforcement discretion to suspend the short-cycle program, allowing LTC pharmacies to dispense 30 (or even 90) day supplies for qualifying medications.

“The revised guidance is consistent with the common-sense policy solutions SCPC has discussed with CMS this past month — and it is now up to the PDPs themselves to expeditiously implement CMS’s recommendations in order to help seniors and the pharmacists who care for them,” Rosenbloom concluded.


The Senior Care Pharmacy Coalition (SCPC) is the only national organization exclusively representing the interests of LTC pharmacies. Its members operate in all 50 states and serve 850,000 patients daily in skilled nursing and assisted living facilities across the country. Visit to learn more.

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