Compliance Concerns for the Medicare Prescription Payment Plan

March 22, 2024

Medicare plans have a long road ahead of them in preparing to administer Medicare Prescription Payment Plan (MPPP). One of the biggest obstacles is ensuring that these payment plans are compliant with US Treasury and Banking regulations, as well as Healthcare regulations. 

Starting January 1, 2025, Medicare beneficiaries will have the option of spreading their out-of-pocket prescription drug costs over the course of their plan year. This is great news for beneficiaries, but Medicare plans have never administered payment plans which opens them up to a world of compliance-related headaches.

Payment and Banking Regulations

Offering payment plans means being subject to regulations like the Truth in Lending Act (TILA). Medicare plans will technically be offering beneficiaries an advance on their out-of-pocket costs, and the TILA, among other things, stipulates organizations must disclose a wide range of information in a specific format to borrowers. 

In addition to the TILA, Medicare plans will have to consider Regulation E (rules and procedures for electronic fund transfers), the Gramm-Leach-Bliley Act (information sharing practices for companies that provide financial services), and even anti-money laundering regulations. This list is not exhaustive, and Medicare plans will not have dealt with anything like this before.

Medicare Advantage and PDP Guidelines

Medicare Advantage plans and Prescription Drug Plans have their own set of guidelines that govern things like communication, payment processes, grievance procedures, and more. While Medicare organizations likely have systems in place to deal with these requirements and fraud protection, those systems do not have provisions for the payment and banking regulations described above. They’re also not likely to have any functionality for calculating and administering payment plans.

MPPP Guidelines

The MPPP comes with its own set of guidelines, and we’ve developed HLTHCard with those guidelines specifically in mind. As it stands, current Medicare plan technology is not up to the task of delivering fully compliant payment plans. HLTHCard is our end-to-end, turnkey solution. It can process transactions, calculate and create payment plans, and send bills—all while remaining compliant with healthcare, banking, and payment regulations. 

If you work for or run a Medicare plan, you probably know that you’ll have to start enrolling MPPP beneficiaries in October. There isn’t much time, but HLTHCard has everything you need. Please contact us to learn more.