2026 Part D Medication Therapy Management Program Guidance
Relevant to: PDF, 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 MTM Program Guidance and Submission Instructions.
Introduction
CMS recently released the guidance memorandum for the 2026 Part D Medication Therapy Management (MTM) programs, essential for ensuring optimal therapeutic outcomes through better medication use. Part D sponsors must submit a program description through HPMS for review and approval. Key dates for program submissions and attestations in 2025 are outlined, helping sponsors maintain compliance with regulatory standards to improve Medicare beneficiary care.
Key Dates and Deadlines
- CY 2026 MTM Program Submission deadline: June 4, 2025, 11:59pm PDT
- CY 2026 MTM Program Attestation deadline: June 18, 2025, 11:59pm PDT
- Release of the CY 2026 MTM Program Submission Module: May 21, 2025, 11:30am EST
- MTM Program Update Cycle windows: September 1-10, 2025; December 1-10, 2025; March 1-10, 2026; June 1-10, 2026; September 1-10, 2026
- Annual Eligibility Threshold effective: January 1, 2025
PACE Compliance
This memorandum includes guidance for Part D Sponsors’ MTM programs for Contract Year 2026. However, PACE organizations are explicitly exempt from these requirements under 42 CFR § 423.153(e). This means that PACE programs do not need to formally establish an MTM program as per these guidelines.
Even though PACE organizations are not required to set up an MTM program, it remains a best practice to ensure quality and effectiveness in medication use among their beneficiaries. Ensuring that medications are used appropriately to optimize outcomes and minimize adverse effects can still be a valuable goal for PACE programs, although not directly mandated by the requirements stated in this memorandum.
Required Actions
All Part D sponsors are required to develop an MTM program to ensure appropriate use of Part D drugs and reduce risks of adverse events. They must refer to the ‘Contract Year 2025 Part D Medication Therapy Management Program Guidance’ for further guidance.
1. Submit an MTM program description annually through HPMS by the deadline of June 4, 2025, for review and approval by CMS.
2. Follow the standard procedures outlined for the Change Request Submission Process for any adjustments to the MTM program description during specified Update Cycle windows.
3. Ensure all required documentation, including the re-attestation via the HPMS attestation link, is completed accurately and submitted by the appropriate deadlines.
FAQs
- “What is the deadline for the 2026 MTM Program submission?”
- “What is the MTM cost threshold for 2026?”
- “How can sponsors submit MTM program change requests?”
- “What are the Update Cycle windows for MTM program changes?”
- “Can MA-PFFS organizations establish an MTM program?”
Click here for the full MTM Program Guidance and Submission Instructions.
