"After enrollees receive their ANOC in a given year, CMS expects sponsors to select at least one of the following two options for effectuating an appropriate and meaningful transition for enrollees whose drugs will be affected by negative formulary changes in the upcoming year:
Current Enrollees - Part D sponsors that can identify objective information demonstrating that a meaningful transition has occurred (such as the adjudication of an exception request and/or evidence of a new prescription claim for a formulary alternative paid by the sponsor prior to the start of the new contract year) do not have to provide a transition supply in the new contract year for that beneficiary as the next fill would either be a covered fill of the medication approved under the exception process or a covered fill of the formulary alternative that the enrollee transitioned to before the start of the new contract year.(source: Medicare Prescription Drug Benefit Manual Chapter 6 – Part D Drugs and Formulary Requirements, 30.4.5 - Transition Across Contract Years, (Rev. 18, Issued: 01-15-16, Effective: 01-15-16; Implementation: 01-15-16)) [emphasis and formatting added]
However, lacking such documentation, the sponsor is expected to provide a transition supply in the new contract year and provide the corresponding transition notice.
New Enrollees - Part D sponsors must extend their transition policies across contract years should a beneficiary enroll into a plan with an effective enrollment date of either November 1 or December 1 and need access to a transition supply. For example, if a beneficiary enrolls effective December 1, in a plan whose transition policy affords a 90-day transition period for LTC enrollees and that beneficiary requires a transition supply in mid-December, the sponsor must offer a full 90-day transition period beginning December 1 and extending into the following contract year.
In addition, sponsors must send beneficiaries with a November 1 or December 1 effective enrollment date an ANOC as soon as practicable after the effective enrollment date. This ANOC will still serve as advance notice of any formulary or benefit changes in the following contract year."