CMS Finalizes Part D Cost-Sharing Smoothing Guidance

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….
By: Manatt, Phelps & Phillips, LLP