Lexology September 17, 2024
Sidley Austin LLP

Beginning in January 2025, Medicare Part D prescription drug plans, including stand-alone and Medicare Advantage Part D Plans, must provide enrollees with the option to smooth their out-of-pocket (OOP) prescription drug costs (capped at $2,000 in CY2025) evenly throughout the plan year. This program, formally known as the Medicare Prescription Payment Plan or M3P, was established as part of the Inflation Reduction Act of 2022 and has the potential to meaningfully improve patient adherence to Part D prescription medications and thereby improve health outcomes while helping to manage patient monthly expenses during the calendar year. The program may therefore affect pharmaceutical manufacturers, particularly with respect to their patient assistance and affordability programs for Part D enrollees.

Mechanics of the Program

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