About | HeinOnline Law Journal Library | HeinOnline Law Journal Library | HeinOnline

1 1 (January 30, 2025)

handle is hein.crs/goveshj0001 and id is 1 raw text is: 





   ;& ~nforming the aegislative debate sic 1914


                                                                                                January 30, 2025

Medicare Part D Premium Stabilization Demonstration


Introduction
Medicare Part D is a voluntary federal program that
provides outpatient prescription drug coverage to 54 million
beneficiaries. Premiums for Part D plans are influenced by
various factors, including plan costs, federal subsidies, and
beneficiary enrollment choices. The Inflation Reduction
Act (IRA; P.L. 117-169) redesigned the Part D benefit to
lower out-of-pocket prescription drug costs. In response to
the IRA and other contributing factors, the Centers for
Medicare & Medicaid  Services (CMS) announced a new
Part D Premium Stabilization Demonstration (the
demonstration) in July 2024, intended to reduce premiums
and plan sponsors' liability. This In Focus provides an
overview of the demonstration, its impact on premiums,
CMS's  statutory authority to create the demonstration, and
considerations for Congress.

Overview of the Med care Part D Benefit
Medicare Part D coverage is provided by private health
payers (plan sponsors) that contract with CMS to offer
stand-alone prescription drug plans (PDPs) or Medicare
Advantage (MA)  plans with drug coverage (MA-PDs).
Each calendar year, CMS releases guidance detailing the
standard Part D benefit, which includes specifications on
annual deductibles, enrollee cost-sharing, and an out-of-
pocket maximum.  Plan sponsors submit annual bids to
CMS  that project the cost of providing either the standard
benefit or an actuarial equivalent in a given region. If the
actual plan costs differ from the projected costs, the plan's
responsibility for any upside or downside risk is outlined
through specified risk corridors.

In addition to the annual deductibles and coinsurance
defined in the standard benefit, many Medicare Part D
enrollees pay a plan-specific monthly premium. This
monthly premium  is calculated by CMS and is derived from
the plan costs in annual bids. CMS derives the base
beneficiary premium (BBP) as 25,5% of the National
Average Monthly  Bid Amount (NAMBA),   adjusted for
government reinsurance subsidies. Reinsurance subsidies
are paid to plans on behalf of an enrollee to offset costs
exceeding a certain threshold. Premiums may vary widely
between MA-PDs   and PDPs, with MA-PDs  generally
offering lower premiums because MA plans are required to
use any MA  rebates they earn to lower patient cost-sharing,

Factors  infuendng Medicare Part D
Premiums n 2025
Congress made a number of changes to the Medicare Part D
standard benefit via the IRA. Prior to the enactment of the
IRA, the Part D standard benefit contained four phases: a
deductible phase, an initial coverage phase, a coverage gap
(doughnut hole), and a catastrophic phase. Enrollees and
their plans were responsible for some degree of cost-sharing


in each phase, but Medicare paid 80% of the costs via
reinsurance once a beneficiary reached the catastrophic
phase.

The IRA  redesigned the Part D standard benefit by
eliminating the coverage gap phase, reducing enrollee cost
sharing in the catastrophic phase, lowering the catastrophic
threshold, and reducing Medicare reinsurance in the
catastrophic phase to a maximum of 40% of total costs.
These reductions in enrollee out-of-pocket costs and
Medicare reinsurance payments, as well as other IRA
measures (such as the $35 cap on co-pays for insulin and
the new Medicare Prescription Payment Plan), shift the
upfront cost of providing the standard Part D benefit to plan
sponsors while reducing out-of-pocket expenses for
enrollees. To limit the amount of the increased cost to plan
sponsors that is passed on to Medicare enrollees through
premium  increases, the IRA included a premium
stabilization provision which capped the annual BBP
growth at 6%. The cap is enforced through increased
Medicare subsidies paid directly to plan sponsors.

In addition to the IRA, other factors also impact PDPs.
CMS  has altered the Part D risk-adjustment model it uses to
set payments to reflect the Part D redesign and separate
PDP  and MA-PD  scoring, which will differentially affect
payment amounts  to plans. Another influence on plan
premiums  is increased spending on high-cost drugs such as
GLP-I  agonists which drive up overall plan costs and
impact premium calculations. CMS selected three GLP-1
drugs (Ozempic, Wegovy, and Rybelsus) for negotiation
under the Medicare Drug Price Negotiation Program.
Negotiated prices for those drugs are not scheduled to go
into effect until CY2027. An ongoing decline in number of
PDPs  since 2014, with a decrease of 26% in plan offerings
between 2024 and 2025 alone, has made the PDP market
more vulnerable to large enrollment shifts when plan
availability or benefits change, particularly for certain low-
income subsidy eligible individuals who are automatically
enrolled in PDPs based on regional benchmarks,

Premium      Stabi   ization   Demonstration
On July 29,2024, CMS  released the Part D Bid information
for 2025 and announced a further stabilization measure: the
Voluntary Part D Premium Stabilization Demonstration for
PDPs  using its authority in Section 402(a)(1)(A) of the
Social Security Act. After reviewing CY2025 bids, CMS
found a 179% increase in NAMBA  relative to 2024, raising
concerns about PDP enrollment market disruptions.

The voluntary three-year demonstration, which is scheduled
to begin in CY2025, has three components to lower Part D
premiums: (1) participating PDPs will have a $15 direct
subsidy applied to the BBP used in their plan-specific

What Is HeinOnline?

HeinOnline is a subscription-based resource containing thousands of academic and legal journals from inception; complete coverage of government documents such as U.S. Statutes at Large, U.S. Code, Federal Register, Code of Federal Regulations, U.S. Reports, and much more. Documents are image-based, fully searchable PDFs with the authority of print combined with the accessibility of a user-friendly and powerful database. For more information, request a quote or trial for your organization below.



Short-term subscription options include 24 hours, 48 hours, or 1 week to HeinOnline.

Already a HeinOnline Subscriber?

profiles profiles most