CMS's release of the August 21st HPMS memo includes draft guidance on the Medicare Prescription Payment Plan (M3P), which is a payment structure introduced in the IRA designed to spread member cost-sharing for prescription drugs across the plan year. The M3P requires all plans to offer this alternative payment plan to their members and will debut in plan year 2025. This program is designed to help elevate the financial burden of members who incur high out-of-pocket pharmacy costs early in the plan year, but at what cost to the plan sponsor?

Impacts of the Medicare Prescription Payment Plan