Pharmacy Carve-Out: Transition & Communications Activities Timeline

  • Timeline also available in Portable Document Format (PDF)
Important:

The FY 2022 Enacted Budget delays the transition of the Medicaid pharmacy benefit by two years, until April 1, 2023. The below information may be used for historical reference.
Updated April 7, 2021

The following charts provides additional context and information related to the New York State Department of Health´s (NYS DOH) transition and communication activities of the Pharmacy Carve-Out from Managed Care (MC) to Fee-For-Service (FFS), effective May 1, 2021.

Who What When Notes
Managed Care Plans Submission of Prescriber Prevails Prior Authorization Activity to NYS DOH ✔️
7/23/2020		 Includes Prior Authorizations through 6/30/2020.
NYS DOH Final review of plan submitted formulary files & feedback ✔️
8/27/2020		  
Managed Care Plans Audit - Non-Covered Products ✔️
10/1/2020		 Plans should complete review/audit of non–covered products (e.g. non rebate signers) and ensure they are not covered as of 10/1/2020, per the last data file provided by NYS DOH on 7/31/2020. The Department will continue to run data and provide updated files on a regular basis (minimum quarterly).
Managed Care Plans Submit test files of approved Prior Authorizations (PA). ✔️
12/11/2020		 Submit test files to NYS DOH in accordance with testing guidance shared with the Medicaid Managed Care Plans.
Managed Care Plans Formulary file freeze ✔️
12/31/2020		 No changes to be made for on–formulary/off–formulary status. Other maintenance such as adding new drugs, criteria changes due to FDA labeling changes would continue.
NYS DOH Formulary file freeze ✔️
12/31/2020		 No changes to be made for preferred/non–preferred status. Other maintenance such as adding new drugs, criteria changes due to FDA labeling changes would continue.
NYS DOH Submit Report to MCOs related to Erectile/Sexual Dysfunction Drugs and Sex Offender Registry. ✔️
By 12/31/2020		 Last timeframe reported out will be Quarter 2 of Calendar Year (CY) 2020.
Managed Care Plans Formulary file submission to NYS DOH ✔️
1/5/2021		 Includes changes/updates as of as of 12/31/2020, in order to update the Medicaid Managed Care Pharmacy Benefit Information Center.
NYS DOH Deliver daily claims test files to plans ✔️
By 1/8/2021		 Deliver test files to Medicaid Managed Care Plans in accordance with the Interface Control Document specifications (ICD).
Managed Care Plans Submit Approved Prior Authorizations (PAs) to NYS DOH ✔️1/22/2021
b. 4/1/2021
c. 5/7/2021		 PAs will be honored after the transition.
  1. Initial file submission
  2. 1st "Catch–Up" File Submission
  3. 2nd "Catch–Up" File Submission
Managed Care Plans Confirm system readiness for claim denials ✔️
3/1/2021		 Ensure Managed Care Plan systems are ready to deny pharmacy claims effective 5/1/2021.
Managed Care Plans Pharmacy (NCPDP) Claim Encounter Submissions Ongoing, for service dates through 4/30/2021. Ensure that encounters are submitted daily, not more than 1 business day from the date of adjudication of the corresponding claim.
NYS DOH Outpatient Pharmacy Per Member Per Month (PMPM) Payments to plans End 4/30/2021, except for retroactive adjustments Plans may initiate retroactive adjustments when:
  • there was active enrollment prior to 5/1/21 that had not been previously billed for, or
  • a plan billed for a member prior to 5/1/21, for which there was not active enrollment. In this case, the plan would reverse the capitation claim in a subsequent period.
NYS DOH Load Approved Medicaid Managed Care Prior Authorizations (PAs) ✔️2/1/2021
b. 4/9/2021
c. 5/14/2021		 Prior Authorizations approved by Medicaid Managed Care plans will be honored after the transition.
  1. Initial file submission
  2. 1st "Catch–Up" File Submission
  3. 2nd "Catch–Up" File Submission
Managed Care Plans Member Material Changes By 5/1/2021 Make necessary changes to member materials and ID Cards.
NYS DOH Outpatient pharmacy inquiries received by the Plans Beginning 5/1/2021 NYS DOH has provided the process to refer inquires to NYS DOH, to the Managed Care Plans.
NYS DOH Collaborative DUR Continuing After 5/1/2021 Provide DUR information and other related reports that will assist plans with medication adherence and/or disease management programs.
NYS DOH Transition Period 5/1/2021 –7/30/2021 The Department has established a transition period of May 1, 2021 through July 30, 2021. This is to ensure that members can obtain medications through FFS, that had been previously covered by their Medicaid Managed Care Plan without going through prior authorization. During the transition period, members will be provided with a one–time, temporary fill for drugs that require prior authorization under the FFS program (e.g. non– preferred products).
NYS DOH On–Demand Reports a. 3/9/2021
b. 5/1/2021
  1. Provide Managed Care Plans with on-demand report design overview
  2. Provide Managed Care Plans with top priority on-demand reports
NYS DOH Daily Claims File Beginning 5/2/2021 NYSDOH begins delivering daily claims files (including paid, denied and reversed) to the Managed Care Plans.
Managed Care Plans Provider Network Data Set (PNDS) File Submission – Quarter 2 7/22/2021 Submit Quarter 2 PNDS data to NYS DOH including pharmacy network data.

Note: Future PNDS data submissions (Quarter 3 and thereafter) to NYS DOH should exclude pharmacy network data.
Managed Care Plans Pharmacy Benefit Manager Quarterly Report 4/15/2021 Submit quarterly Pharmacy Benefit Manager report.

Note: This will be the last quarterly PBM report submitted by MCPs.
Managed Care Plans Claims submission deadline Per Plan's agreement with their PBM The last day that Managed Care Plans will pay claims for service dates prior to 5/1/2021.
Managed Care Plans Physician Administered Claim Encounter Submissions N/A Physician administered drugs, when billed as an institutional or medical claim, will continue to be provided by the managed care plans and claim encounters will continue to be submitted to NYS DOH.
Managed Care Plans DUR Reports N/A DUR survey for 2021 – Due 7/1/2021, unless CMS delays it for some reason. (It was delayed to 9/30/2020 this year because of COVID.) The reporting period is 10/1/2019 – 11/30/2020.

DUR survey for 2022 – the reporting period is 10/1/2020 – 11/30/2021 (So only member data through 4/30/2021).

Physician administered drug information will continue to be required post carve–out.
Who What When Notes
NYS DOH Website Updates: 11/1/2020 –6/30/2021 Make relevant website updates such as:
  • Notification of carve–out (e.g. a banner)
  • How to find the Medicaid Client Identification Number (CIN) on the Managed Care Plan ID card.
  • Links to relevant Medicaid Update articles
NYS DOH Medicaid Update and Email Blast ✔️
11/2/2020		 Informs pharmacies, prescribers and Durable Medical Equipment (DME) Providers that are not enrolled in Medicaid Fee-For-Service (FFS), of the need to enroll, to continue to serve Medicaid Managed Care members effective 5/1/2021.

Medicaid Update Article: Attention: Pharmacies, Durable Medical Equipment, Prosthetics, Orthotics and Supply Providers, and Prescribers That Are Not Enrolled in Medicaid Fee-For-Service (Pg. 10) - October 2020
NYS DOH Non–FFS–Enrolled Provider Communication 12/7/2020 – 3/19/2021 NYS DOH will send targeted communications regarding the need to enroll in Fee–For–Service (FFS) effective 5/1/2021 to non–enrolled providers (pharmacies, prescribers, and Durable Medical Equipment (DME)).
Managed Care Plans Non–FFS–Enrolled Provider Communication 12/7/2020 – 3/19/2021 Managed Care Plans will send targeted communications regarding the need to enroll in Fee–For– Service (FFS) effective 5/1/2021 to non–enrolled in–network and out–of– network providers (pharmacies, prescribers, and Durable Medical Equipment (DME)).
NYS DOH Medicaid Update ✔️
12/18/2020		 Initial Medicaid Update Article published.

Medicaid Update Article: Special Edition Part One: Medicaid Pharmacy Carve-Out - December 2020
NYS DOH Plan Notice of Benefit Change By 3/2/2021 Pursuant to Section 4.3 of the Medicaid Managed Care/Family Health Plus/HIV Special Needs Plan/Health and Recovery Model Contract, Modification of the Benefit Package Services, the Department of Health (Department) must provide Plans at least 60 days advance notice of modifications to the benefit package.
NYS DOH Medicaid Update 3/12/2021 Second Medicaid Update Article published.
NYS DOH Prescriber Outreach By 3/31/2021 Conduct prescriber outreach activities targeted to inform high volume prescribers of non–preferred products and actions that can be taken to smooth the transition (e.g. change to a preferred product or seek prior authorization).
NYS DOH CBIC Card Carrier Language Update By 5/1/2021 Update Client Benefit Identification Card (CBIC) card carrier language to include applicable information for the pharmacy carve–out.
NYS DOH Update applicable system generated member notices. a. Effective 4/16/2021
b. 5/1/2021		 Conduct appropriate updates to the system generated notices that provide a description of the pharmacy benefit.
  1. NYSOH Member Eligibility Notices for members who enroll in Medicaid via the NYSOH.
  2. Client Notice Subsystem Medicaid Acceptance Notices for members who enroll in Medicaid via their Local Department of Social Services (LDSS)
For more information on where a member should enroll (NYSOH or LDSS) please review the FAQ "How do I apply for Medicaid?" within the General Medicaid FAQs section of the Medicaid in New York State website.
Managed Care Plans Member Notice of Change 3/1/2021 – 3/26/2021 Mail Member Notice of Change per assigned mailing schedule provided by NYS DOH. The Member Notice of Change informs members of the change and that they can use their plan ID Card or their Medicaid Card to access pharmacy services.
Managed Care Plans Website Updates 2/1/2021 – 4/30/2021 Make relevant website updates.
Managed Care Plans Claims Denial Messaging Effective 5/1/2021 Implement claim denial messaging that notifies pharmacies to submit claims to the FFS program.
NYS DOH Custom prescriber notifications By 4/30/2021 Prescribers will be notified of their patients that are on non-preferred products.