2026 PDP Crosswalk Updates & Premium Increase Limits
Relevant to: PDP, 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 Centers for Medicare & Medicaid Services (CMS) has updated guidance on PDP crosswalks, crucial for the Contract Year 2026. This update includes corrections to previous bidding instructions and vital operational updates for Prescription Drug Plan (PDP) crosswalks. CMS emphasizes the newly codified limits on premium increases for plan consolidations, underlining their importance for Medicare participants.
Key Dates and Deadlines
- April 1, 2025: Original guidance issued for Contract Year 2026 Final Part D Bidding Instructions.
- April 23, 2024: Final Rule regarding crosswalk policy changes published in Federal Register.
- June 2025: Due date for submission of crosswalk exception requests for CY 2026.
- First Monday in June 2025: Date by which preliminary bids must be submitted for CY 2026.
- Summer 2025: Announcement of National Average Monthly Bid Amount, Part D Base Beneficiary Premium, and related information.
PACE Compliance
The guidance memo addresses changes and updates surrounding the Prescription Drug Plan (PDP) crosswalks and premium stabilization for Contract Year (CY) 2026. Although this memo does not directly mention Program of All-Inclusive Care for the Elderly (PACE) programs, there may be indirect implications for PACE organizations in terms of regulatory compliance, particularly if they are considering any contract consolidations or crosswalk exceptions.
The key compliance requirements outlined in the memo, potentially relevant to PACE entities, are as follows:
- The memorandum clarifies the crosswalk rules under 42 CFR § 423.530, emphasizing the limits on premium increases during consolidation or crosswalking of PDPs. This implies that any consolidation or crosswalk involving PACE-related plans should adhere to these outlined premium increase limits to remain compliant with CMS regulations.
- The examples provided in the memo demonstrate how premium increases should be calculated in accordance with existing BBP and EA PBP premiums. PACE organizations involved in such processes must ensure their premium calculations abide by these standards to avoid compliance issues.
- The demonstration project outlined, which involves premium stabilization for stand-alone PDPs, could serve as a useful model for future changes or adjustments within PACE programs. Monitoring the outcomes of such demonstrations may provide insights into how similar adjustments can be approached for PACE plans should they consider future participation in any comparable initiatives.
For any plans under PACE affected by these guidelines, it would be essential to calculate premium changes correctly, keeping within the CMS specified limits to ensure compliance and avoid potential suppression from Medicare listings.
Required Actions
1. Review the updated guidance from CMS on PDP crosswalks for CY 2026, particularly focusing on the newly specified limits on premium increases for consolidated renewal and contract consolidation crosswalks.
2. Evaluate any potential premium changes for your PDP plans based on the CY 2025 premiums, considering the reductions from the demonstration, and prepare for the submission of bid information by the first Monday in June 2025.
3. Prepare and submit crosswalk exception requests in accordance with the updated instructions, ensuring compliance with the applicable regulation at 42 CFR § 423.530(c) and the principles outlined by CMS to prevent unanticipated large increases in premiums.
FAQs
- “What updates were provided regarding PDP crosswalks for Contract Year 2026?”
- “How does the April 2024 Final Rule impact premium increases for PDP consolidated renewals?”
- “What are the guidelines for crosswalk exception requests for CY 2026?”
- “How will CMS assess potential premium changes for CY 2026 crosswalk exception requests?”
- “What is the Part D Premium Stabilization Demonstration and its impact on premium limits?”
