2026 Part D Pricing Data Submission Guidelines & Updates
Relevant to: PDP, Drug Pricing, 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 to read the complete memo from CMS.
Introduction
The Department of Health and Human Services issued a memo detailing the submission guidance for the 2026 Part D Pricing Data. This guidance is crucial for Part D sponsors as it outlines the use of the Health Plan Management System (HPMS) for submitting drug pricing and pharmacy data. The memo introduces new features for the upcoming year, including validations for maximum fair prices under the Medicare Drug Price Negotiation program and options for custom dispensing fees for different day supplies.
Key Dates and Deadlines
- May 27, 2025: Memo issued to all Part D Plans
- June 27, 2025: Release of CY 2026 module to all Part D sponsors
- June 30 – July 3, 2025: Test submission #1 window for CY 2026 pricing
- July 21 – July 24, 2025: Test submission #2 window for CY 2026 pricing
- August 6 – August 12, 2025: First preview of CY 2026 drug pricing data
- August 11 – August 14, 2025: Test submission #3 window for CY 2026 pricing
- August 25 – August 28, 2025: Final submission for CY 2026 pricing before open enrollment
- September 2 – September 5, 2025: Second preview of CY 2026 drug pricing data
- September 8 – September 11, 2025: First production cycle for CY 2026 pricing data
- October 1, 2025: Launch of CY 2026 drug pricing data on MPF
PACE Compliance
This memo generally pertains to Part D plans, which involve Medicare drug benefit programs. PACE (Program of All-Inclusive Care for the Elderly) is a separate type of Medicare and Medicaid program that provides comprehensive medical and social services to certain elderly individuals who are frail and need nursing home level care. Therefore, most sections of this memo are not directly relevant to PACE compliance, as PACE does not typically engage in the Part D pricing data submissions outlined.
However, it is important to note that while PACE plans are generally exempt from submitting regular Part D pricing data, there are compliance elements related to accuracy and completeness that could still be relevant.
- PACE plans must ensure that any data they are required to submit to CMS, such as formularies and benefits that may influence or be similar to Part D submissions, are complete and accurate.
- Failure to comply with these requirements could result in compliance actions similar to Part D plans where inaccuracies in data could lead to issues with program requirements or data presentation.
- It is advisable for PACE organizations to stay informed on CMS communications and guidelines that may occasionally affect or be relevant to broader Medicare data or reporting requirements, ensuring they remain compliant.
This memo mostly deals with information regarding Part D plan specifics and thus requires minimal direct action from PACE organizations unless otherwise specified by subsequent CMS directives.
Required Actions
1. Access the Health Plan Management System (HPMS) Part D Pricing File Submission (PDPFS) module on June 27, 2025, when the CY 2026 module is released, to start preparing for the submission process.
2. Prepare and submit all relevant drug pricing and pharmacy data using the appendix E layout if you are opting for different dispensing fees for selected drugs, ensuring all required fields are filled without null values.
3. Ensure compliance with new CY 2026 validations and submission rules, including setting up API protocols if opting to submit pricing files automatically, and completing necessary attestations in HPMS.
FAQs
- “What is the Health Plan Management System (HPMS) and how is it used for Part D pricing data submission?”
- “How can Part D sponsors correct errors in their pricing data submissions?”
- “What changes are expected for the CY 2026 drug pricing submissions?”
- “How do Part D sponsors submit dispensing fees for selected drugs with different day supply options?”
- “What is the role of an API in the Part D Pricing File Submission process?”
The memo provides guidance for Part D sponsors on submitting drug pricing and pharmacy data using the Health Plan Management System (HPMS). Taxonomies and corrections procedures are detailed, including the resubmission of corrected data during specified windows. Changes for CY 2026 include new validation steps and drug negotiation program pricing considerations. Dispensing fees for selected drugs can vary by day supply, with specific fields added for reporting. Additionally, Part D sponsors can use the API to streamline submissions and automate interaction with the submission module.
