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Improve Transparency, Data Collection, and Plan Oversight

All Part D appeals conversations are hampered by limited data and transparency in the process. Beneficiaries and advocates alike can struggle not only to track an individual’s specific claims, but also plans’ or system-wide patterns that may be tied to hundreds of thousands of Medicare beneficiaries improperly going without their needed medication. Further, better data could lead to better solutions, as a more transparent system will lend itself to targeted recommendations and self-correction. Congress should require CMS to conduct and make publicly available a comprehensive, in-depth analysis of the Part D appeals process. In part, this analysis should include data collection on specialty tier medications and should extend to all levels of appeals, from plans through the Medicare Appeals Council and federal court.