Contract Year 2025 Bid Review Out-of-Pocket Cost (OOPC) Models

Relevant to: Pharmaceutical Manufacturers; All Part D Plan Sponsors

The Inflation Reduction Act of 2022, Public L. 117-169 (IRA), established the Medicare Part D Manufacturer Discount Program (Discount Program) that begins on January 1, 2025. Since publication of the Medicare Part D Manufacturer Discount Program Final Guidance and the Medicare Part D Manufacturer Discount Program: Methodology for Identifying Specified Manufacturers and Specified Small Manufacturers on November 17, 2023, CMS has received technical questions from manufacturers, Part D sponsors, and other interested parties regarding the policies and methodologies described in those documents. The attached document is intended to provide clarifying responses to those questions.

See the full guidance for more information.