CY 2022 Clawbacks: Increases, But How Large?
The Centers for Medicare & Medicaid Services (CMS) recently notified states of next year’s clawback multipliers, which are used to determine state cost-sharing payments to the federal government for the Medicare Part D prescription drug program. According to the CMS release, the per-beneficiary monthly clawback charge will increase by 7.31% in calendar year (CY) 2022, the same as the increase announced earlier this year because no additional adjustments were required.
The Federal Medical Assistance Percentage (FMAP) affects the clawback multipliers. Because the end date of the COVID-19-related, temporary 6.2 percentage-point increase in the FMAP is unknown, CMS provided two multipliers for each state: with and without the FMAP increase. If the temporary FMAP increase runs through March 2022 (based on the current public health emergency [PHE] renewal), FFIS estimates that CY 2022 clawbacks will cost states $14.2 billion, a $2.5 billion (21%) increase from CY 2021. Clawback costs based on alternative assumptions about the PHE end date are also provided, with overall annual increases ranging from 7.3% to 16.4%.