On November 17, 2023, CMS released final program guidance to pharmaceutical manufacturers and Part D plan sponsors for implementing the Medicare Part D Manufacturer Discount Program for 2025 and 2026. This paper summarizes the key provisions of the MDP final guidance and other subsequent guidance, including a summary of programmatic differences and similarities to the previous Coverage Gap Discount Program (CGDP), an analysis of the impact of a phase-in of manufacturer discounts, and its potential implications to various stakeholders.

From Coverage Gap to Member Cap: Understanding the New Landscape of Medicare Part D Manufacturer Discounts