Can I ask my Medicare drug plan for a formulary exception before the January 1st start of the new coverage period?

"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:

• Provide a transition process for current enrollees at the start of the new contract year.  In order to prevent coverage gaps, sponsors choosing this option are expected to provide a transition supply of the requested prescription drug beginning January 1 and provide enrollees with the required transition notice; or
  
  
• Effectuate a transition for current enrollees prior to the start of the new contract year. In effectuating this transition, sponsors must aggressively work to (1) prospectively transition current enrollees to a therapeutically equivalent formulary alternative; and (2) adjudicate any requests received for exceptions to the new formulary prior to the start of the contract year -- consistent with chapter 18, section 30.2.2, [available at https://www.cms.gov/Medicare/ Appeals-and-Grievances MedPrescriptDrugApplGriev/Downloads/Chapter18.zip -- no longer online]
  
  However, if sponsors have not successfully transitioned affected enrollees to a therapeutically equivalent formulary alternative or adjudicated an exception request prior to January 1, they will be expected to provide a transition supply beginning January 1 and the required transition notice. If a sponsor approves an exception request pursuant to this section, the sponsor must authorize payment prior to January 1 of the new contract 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.

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."