2025 Medicare Part D Low-Income Subsidy Updates and Resource Standards

Relevant to: PDP, PACE, Part D

Each week, we scan the latest CMS memos to find the most important ones that apply for PACE programs. Below is a summary of what you need to know.

Disclaimer: The content provided on this site is a summary for informational purposes only, and Grane PBM, Inc. assumes no liability for any errors or omissions in the site’s content. The information does not constitute legal or regulatory advice or replace the original CMS memo. Readers are advised to consult the CMS memo in its entirety and to verify information independently before making any decisions based on this information.

Click here for the full guidance on 2025 Medicare Part D Low-Income Subsidy (LIS) Income and Resource Standards.

Introduction

The Centers for Medicare & Medicaid Services has published the 2025 Medicare Part D Low-Income Subsidy (LIS) Income and Resource Standards, crucial for beneficiaries seeking financial assistance. This update includes income and resource thresholds reflecting the latest poverty guidelines, applicable to all LIS applications filed from January 1, 2025. Additionally, the memorandum details the methodology used for adjusting these thresholds and includes insights on beneficiary cost-sharing adjustments.

Key Dates and Deadlines

  • Date of Memo: February 12, 2025
  • Release of updated Poverty Guidelines to plans: October 31, 2024
  • Application of new income and resource standards for LIS: January 1, 2025

PACE Compliance

This memo is relevant to PACE programs due to the necessity of staying compliant with the updated income and resource standards for the low-income subsidy (LIS) for Medicare Part D. It is essential for PACE organizations to ensure that LIS applications filed on or after January 1, 2025, align with these updated standards.

The updated poverty guidelines and resource limits outlined in the attachments of this memorandum are crucial for determining eligibility and ensuring compliance with Part D LIS. It is important for PACE programs to review these guidelines critically:

 

  • The updated 2025 Poverty Guidelines for the contiguous 48 states and the District of Columbia, Alaska, and Hawaii.
  • The methodology used by CMS to update the resource limits.
  • The updated cost-sharing amounts for LIS-eligible beneficiaries.

 

For continued compliance:

  • PACE organizations must use the annual adjustment for CY 2025 to evaluate eligibility for the full low-income subsidy and ensure that resource limits, copayments, and other factors are correctly applied.
  • Verify that all beneficiaries’ resources fall within the specified limits to remain eligible for LIS benefits in CY 2025.
  • Update any relevant procedures and systems to incorporate these changes and ensure accurate calculations and submissions moving forward.

 

Failure to comply with these updates may result in discrepancies and non-compliant submissions that could lead to potential financial discrepancies within PACE plans and issues in beneficiary approvals.

Required Actions

HTML_required_actions: Review the updated income and resource standards for the 2025 Medicare Part D Low-Income Subsidy (LIS), including the attached tables for the 2025 Poverty Guidelines and resource limits for eligibility.

2. Apply the new income and resource standards to all LIS applications filed on or after January 1, 2025.

3. Direct any questions or clarifications regarding the information in the memorandum to Roland Herrera at the provided email address.

FAQs

  • “What are the 2025 Medicare Part D Low-Income Subsidy (LIS) income and resource standards?”
  • “How are the poverty guidelines adjusted annually for different states?”
  • “What methodology is used to update the resource limits for the Low-Income Subsidy?”
  • “What are the maximum cost-sharing amounts for LIS-eligible beneficiaries in 2025?”
  • “How do resource limits affect eligibility for the full low-income subsidy?”

Click here for the full guidance on 2025 Medicare Part D Low-Income Subsidy (LIS) Income and Resource Standards.

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