February 15, 2024



On February 15, 2023, CMS published memorandum, “Medicare Prescription Payment Plan: Draft Part Guidance on Select Topics, Implementation of Section 1860D-2 of the Social Security Act for 2025, and Solicitation of Comments.” The Medicare Prescription Payment Plan, a provision of the Inflation Reduction Act (IRA) of 2022, goes into effect January 1, 2025, and requires Medicare prescription drug plans to offer program participants who elect to enroll in the Medicare Prescription Payment Plan the ability to pay their prescription drug out-of-pocket costs via monthly payments as opposed to at the pharmacy point-of-sale. The draft part two guidance follows the draft part one guidance that was released on August 21, 2023, as well as technical guidance on the calculation of the maximum monthly cap on cost-sharing payments, released on July 17, 2023.


The draft part two guidance outlines CMS’ requirements for outreach and education, pharmacy processes, and operational considerations for the Medicare Prescription Payment Plan. Comments regarding the draft part two guidance should be sent to PartDPaymentPolicy@cms.hhs.gov with the subject line “Medicare Prescription Payment Plan Guidance – Part Two” no later than March 16, 2024.


  • The draft part two guidance can be found on the CMS IRA website, here.


  • The fact sheet for the draft part two guidance can be found on the CMS IRA website, here.

Contact us at info@bluepeak.com to discuss the operational implications of the Medicare Prescription Payment Plan and ensure successful implementation of provisions!

BluePeak Advisors is a division of Gallagher Benefit Services, Inc. 

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