John Cohn finds the December GAO report that says that CMS wasn’t ready for Part D’s launch, and also McClelland’s response that the GAO was underestimating CMS. Make that “mis-underestimating”, I think. 

Here’s what the GAO Report says would be some likely problems with Part D’s introduction for the dual eligibles:

For dual-eligible beneficiaries who do not have Medicare drug coverage because they were either not identified and enrolled on January 1, 2006 or are newly qualified dual-eligible beneficiaries, CMS has developed a point-of-sale enrollment mechanism designed to enable pharmacies to assist these beneficiaries in obtaining immediate Part D coverage. The agency signed a contract with a designated PDP on November 22, 2005 to implement this mechanism. Because these arrangements were completed less than 6 weeks before the transition is to occur, limited time remains to educate all pharmacies about its availability and details of its operation.

For beneficiaries who were enrolled in a PDP but do not have their PDP information, CMS has facilitated a new information-technology process, known as the Eligibility Transaction, that will allow pharmacies to identify a beneficiary’s PDP and provide the beneficiary with the PDP’s contact information. As with the point-of-sale enrollment mechanism, it is unclear to what extent pharmacies are informed about the Eligibility Transaction and will use it. Despite CMS efforts to publicize this tool to industry organizations, a pharmacy industry association representative stated that it is unclear how many independent drug stores, which dispense the majority of the nation’s retail prescription drugs, plan to use the Eligibility Transaction.

Translation: a) Pharmacies are supposed to be able to immediately register dual-eligibles if they’re not already in a PDP but that was only developed in November and wouldn’t be ready. b) GAO was unsure how many pharmacies would use the eligibility transaction system.

GAO didn’t seem to predict what apparently is the major problem — the data on eligibility from the PDP’s that the transaction database is hitting against is wrong or it’s just not working.

We will find out more, but they had two years to get this right! And it seems to be getting worse!