Medicare Prescription Drug Benefit and Medicare Advantage FIinal Regulations

Introduction

Crowell & Moring LLP's HealthCare Group is pleased to provide our clients and visitors to our Website with the following analysis of the Medicare Prescription Drug Benefit and Medicare Advantage final regulations. Rather than attempt to summarize 548 Federal Register pages of preambles and regulations, our analysis focuses on the changes between the proposed and final regulations and the commentary that explains those changes. We have also tried to note the many instances in which CMS promised later guidance to address matters not covered in the final rules.

Please click on the links below to view Crowell & Moring's analysis.

• Summary of Title I MMA Regulations
  
• Summary of Title II MMA Regulations
  

The above summaries are not a substitute, of course, for a careful review of the regulations and commentary themselves. To assist your further review, here are links to the Federal Register¹ version of the regulations:

Title I (Prescription Drug Plan) Final Regulations
Title II (Medicare Advantage) Final Regulations

Equally obviously, Crowell & Moring's HealthCare Group would be happy to help you with the interpretation and application of these regulations. Feel free to call your regular Crowell & Moring contact or any of the authors listed below.

Kenneth M. Bruntel
Editor

1. Unless otherwise indicated all “FR” page references are to Volume 70 of the January 28, 2005 Federal Register. Also unless otherwise noted, cites to Code of Federal Regulations sections ( e.g. , § 423.1) are to 42 CFR.