This overview is excerpted from Manatt on Health, Manatt’s subscription service that provides in-depth insights and analysis focused on the legal, policy and market developments.

The Centers for Medicare & Medicaid Services (CMS) finalized the second part of its guidance on implementation of the IRA’s Medicare Prescription Payment Plan (MPPP), known informally as Part D monthly out of-pocket “smoothing”. This was one of the last major pieces of guidance left outstanding before implementation of MPPP elections begin during this fall’s Medicare open enrollment period for 2025.

Among the few notable changes from the draft guidance are a change to the criteria Medicare prescription drug plan (PDP)  sponsors must use to identify beneficiaries likely to benefit from MPPP during the plan year. Sponsors must still notify pharmacies when beneficiaries incur a prescription with more than $600 in excess cost but are no longer required to do targeted outreach based on prior authorization or other utilization management edits. CMS has also given more specificity to the processes needed to notify beneficiaries about the program when they are in a long-term care setting.