PCMA Urges CMS to Stabilize the Medicare Part D Plan Marketplace

By Tim Dube, SVP, Policy and Regulatory Insights, Pharmaceutical Care Management Association

Last week, PCMA offered recommendations to the Centers for Medicare and Medicaid Services (CMS) aimed to help stabilize the Medicare Part D marketplace and protect valuable pharmacy benefits for America's seniors, in advance of CMS's annual rulemaking and guidance cycle. CMS will soon be releasing the CY 2026 Part C and D Policy and Technical Rule (CY 2026 Rule) and the CY 2026 Advance Notice of Methodological Changes (Advance Notice), which will impact millions of seniors covered by Medicare Part D plans.

In the letter submitted last week, PCMA offers two specific policy recommendations related to the redesign of Part D benefits.

• Consider Revising the Interpretation of "Incurred Costs" for Enhanced Alternative Plans: CMS should revise its interpretation of section 1860D-2(b)(4)(C)(iii)(II) to exclude supplemental coverage from enhanced alternative PDPs, as the current approach creates financial disincentives for plan sponsors and is not supported by statutory language. In the long run, this has the potential to slow or reverse carrier exit from the PDP market.
• Lower the Meaningful Difference Threshold to 10%: CMS should reduce the meaningful difference threshold from 15% to 10% to provide Part D plan sponsors with more flexibility in designing plan benefit packages, especially considering the significant improvements to the value of the standard Part D benefit introduced by the IRA.

Second, PCMA reiterates concerns regarding implementation of the Inflation Reduction Act's payment policies for pharmacies dispensing one of the 10 drugs with prices set by the government. Because the statute is clear that responsibility for these payments fall to those drugs' manufacturers, PCMA recommends that CMS Keep the Burden for MFP Effectuation on Manufacturers, not Part D plans.

PBMs will continue to work with CMS to help Medicare beneficiaries access affordable prescription drugs and create an efficient, fair regulatory system.

View PCMA's full comment letter HERE.

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PCMA is the national association representing America's pharmacy benefit companies. Pharmacy benefit companies are working every day to secure savings, enable better health outcomes, and support access to quality prescription drug coverage for more than 275 million patients.