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A rule that decides appeals

The formulary, tiering and step-therapy exception

Every Medicare Part D plan, and marketplace plans under the essential-health-benefit rule, must grant an exception to cover a non-formulary drug, charge a lower tier or waive step therapy when the prescriber states that the covered alternatives would be less effective or harmful for you. The prescriber's statement is the whole case; the appeal is the request done properly.

Last reviewed Sep 11, 2026 · General information, not legal advice · Apellica is not a law firm · the plan documents and the letter control

When it applies

  • Part D coverage determinations: non-formulary, tiering, step therapy, quantity limits
  • Marketplace and individual plans (45 CFR 156.122(c)): 72-hour standard and 24-hour expedited decisions
  • Medicare Advantage step therapy for Part B drugs (42 CFR 422.136)

Where it does not

  • Drugs excluded from Part D by statute
  • A plan-design exclusion of a whole category, which needs a different argument

The sentence to put in the appeal

I request a [formulary / tiering / step-therapy] exception under [42 CFR 423.578 / 45 CFR 156.122(c)]. The prescriber's attached statement establishes that [the formulary alternatives have been tried and failed / are contraindicated / would be less effective or cause adverse effects for me]. Please decide within the applicable timeframe [72 hours; 24 hours expedited] and, if denied, treat this as a request for redetermination.

Replace the bracketed parts with your facts. Cite the regulation exactly as written; quote the plan’s own wording next to it.

How to use it

  1. Step 1

    Get the statement, not a note

    Which alternatives, what happened, why the requested drug; dates and records.

  2. Step 2

    Ask for expedited handling when waiting hurts

    The 24-hour clock applies when the standard timeframe could seriously jeopardise health or the ability to regain function.

  3. Step 3

    Calendar the renewal

    Part D approvals generally run through the plan year; commercial plans set their own term.

Worked example

A migraine drug was denied as non-formulary. The neurologist's statement listed three failed preventives with dates; the exception was approved in two days under the 72-hour rule.

Illustrative composite; details vary by plan and record. Outcomes are not guaranteed.

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