Relevant to: All Part D Sponsors
The purpose of this memorandum is to remind Part D sponsors of the CMS memorandum released July 24, 2023, entitled “REVISION – Contract Year 2023 Program Guidance Related to Inflation Reduction Act Changes to Part D Coverage of Vaccines,” which announced revised program guidance related to determining when $0 cost sharing applies for adult vaccines covered under Part D. Specifically, in the revised guidance, CMS instructed that the effective date of the $0 cost-sharing requirement for a new adult vaccine recommended by the Advisory Committee on Immunization Practices (ACIP) must align with the date on which the CDC Director adopts the respective recommendation, as published on the CDC website, or the date after the last day of the ACIP meeting at which the recommendation was approved, if no date is published on the CDC website. While this CMS guidance revision became effective as of the date of the memorandum, July 24, 2023, we clarify that it retroactively applies to commercially available ACIP-recommended adult vaccines adopted by the CDC Director during previous 2023 ACIP meetings.
