On January 31, 2024, the Centers for Medicare and Medicaid Services (CMS) released draft instructions on the CY2025 Part D Redesign. These draft instructions touch on many of the outstanding Part D benefit adjudication questions that the industry has been asking. It lays out True-Out-of-Pocket
eligible claims and their application to deductible & out-of-pocket thresholds, as well as methodologies for calculating reinsurance, medical loss ratio, risk corridor, and Out-of-pocket cost /meaningful difference. In these instructions, CMS also released additional guidance on Employer Group Waiver Plans.

Summary of Draft CY2025 Part D Redesign Program Instructions