ACS CAN comments on Part D Explanation of Benefits

As Congress debated the Inflation Reduction Act (IRA) we strongly advocated for both an annual cap on total Part D out-of-pocket costs and a mechanism that would allow an enrollee the option to pay the required cost-sharing in capped monthly installments. We are pleased the proposed changes to the Part D EOBs reflect the imposition of the Part D cap, beginning in plan year (PY) 2024. As CMS begins to implement the provision of the IRA that allows beneficiaries the option to smooth their cost sharing over the course of the plan year, we strongly encourage CMS to conduct robust education and outreach to inform beneficiaries of this new and important consumer benefit.

We recognize that the option to elect a maximum monthly cap has never before been implemented in the Medicare program. Enrollees will need clear and concise information educating them about their option to elect a maximum monthly cap. We strongly encourage CMS to use the EOB (1) as a mechanism to inform Part D enrollees about their opportunity to elect to have their monthly prescription drug costs capped, and (2) to inform beneficiaries who have already elected to have their monthly prescription drug costs capped of their remaining financial obligations.