Medicare Prescription Payment Plan will benefit patients if implemented correctly

In comments submitted yesterday, PhRMA responded to draft guidance for implementing the Medicare Prescription Payment Plan (MPPP), a new program created by the Part D redesign provisions in the Inflation Reduction Act (IRA). The MPPP requires Part D insurance plans to provide Part D beneficiaries the option to pay out-of-pocket prescription medicine costs through monthly billed payments spread over the calendar year, instead of all at once at the pharmacy.

PhRMA has long advocated for a cap in Part D out-of-pocket costs coupled with a monthly cost-sharing cap as key affordability improvements in Part D. PhRMA agrees the MPPP will improve patient affordability and beneficiary access to medicines if proper education and outreach is conducted to ensure seniors and people with disabilities are aware of and understand the program and its potential benefits. Our feedback includes: 

• Encouraging CMS to launch a broad education campaign to raise awareness of the MPPP and other changes made to Part D through the redesign, as well as allowing beneficiaries to make an informed decision about whether election in the MPPP is right for them.
  
  
• Supporting CMS’s beneficiary-focused approach to the MPPP, including the creation of an interactive tool to help seniors model out their month-to-month costs through the MPPP.
  
  
• Urging CMS to continue developing processes to ensure Part D beneficiaries will be able to seamlessly opt into the MPPP at the point of sale in the first year of implementation.
  
  
• Commending CMS for proposing protections in the draft guidance that ensure Part D beneficiaries benefit from the MPPP, balancing beneficiary access and patient protections with plan operational and financial considerations.

However, PhRMA is concerned that other elements of the IRA could undermine these gains by disrupting Part D plan and formulary designs and increasing patient barriers to medicines. For instance: 

• Part D insurance plans are required to cover medicines that are selected for price setting, but nothing in the IRA prohibits them from imposing utilization management to restrict access to medicines in Part D. 
  
  
• Insurers can also move Part D medicines to more expensive, non-preferred and specialty formulary tiers that have higher out-of-pocket costs. 
  
  
• Part D plans may stop covering some medicines altogether since they are only required to cover a minimum of two medicines in most therapeutic classes, which could be the price-set medicine and one other.

Implementing these significant changes to Part D requires thoughtful consideration. Read our full comments.