CMS has reminded Part D prescription drug plans that Medicare beneficiaries taking topical ophthalmic products (eye ointments or creams) may have a legitimate need for an "early refill," since the medication is self-administered and cannot be "as easily measured or controlled" as tablets or capsules.

Accordingly, the CMS memo reiterates that Part D plans must have a mechanism to allow beneficiaries to receive an early refill for these medications, so that beneficiaries are not unreasonably put "at risk of interruptions in drug therapy that potentially have serious consequences."

You can get the reminder memo on CMS' website at https://www.cms.gov/PrescriptionDrugCovContra/Downloads/MemoEarlyRefillOpth_06.02.10.pdf