Crosswalk

Part D Model EOB Crosswalk
60-Day PRA Package
Model 2023 EOB and
instructions (old version)
Throughout

Instructions – Drug Pricing
Information

Instructions – Drug Pricing
Information

Instructions: Other things to know
Instructions – Other things to know

Instructions – Other things to know

Instructions – Other things to know

N/A

N/A

1

Model 2025 EOB and
instructions (new version)
Updated year to 2025. Updated
months in exhibits to reflect
benefits used in March and an EOB
provided in April.
Revised instructions to remove
“appropriate” and include that
“plans should use their clinical
expertise when deciding which
alternative drugs to list”.
Revised “gross drug spend or
TrOOP” as “gross covered
prescription drug costs or true outof-pocket (TrOOP) amounts”.
Revised as “Important things to
know”
Redefined “Extra Help” as referring
to the low-income subsidy (LIS)
described in Subpart P of the Part D
regulations.
Redefined “Out-of-Pocket Costs”
and “TrOOP” as referring to the
enrollee’s incurred costs, as defined
at 1860D-2(b)(4)(C).
Redefined “Total Drug Costs” as
referring to gross covered
prescription drug costs, as defined
at 1860D-15(b)(3).
Added to Instructions – Important
things to know: “Do not provide
information in the Part D EOB
about drugs or supplies that would
be covered for a beneficiary in
original Medicare under Parts A
and/or B; for an enrollee in a Part C
plan under the plan’s Part A/B
coverage.”
Added to Instructions – Important
things to know: “In charts 1, 1A,
and 2, the amounts to be used for
‘you paid’ are the final amounts
after ‘other payments’ (those made
by programs, organizations, or
other plans; ‘other payments’ may
include TrOOP and non-TrOOP
amounts).”

Type of Reason for
Change1 Change
Rev.
Accuracy

Burden
Change2
Yes

Rev.

Clarity

No

Rev.

Clarity

No

Rev.

Clarity

No

Rev.

Clarity

No

Rev.

Clarity

No

Rev.

Clarity;
Statutory
change

No

Add

Clarity;
moved from
Chart 1
instructions.

No

Add

Clarity

Yes

Types of Change: Rev. = Revision, Del. = Deletion, Add = Addition
We estimate the changes to the Part D Model EOB, overall, will increase the one-time burden for a business operations specialist to
program the model template into plan systems. See sections 12 and 15 of the Supporting Statement for detailed discussion.
2

Model 2023 EOB and
instructions (old version)
Throughout

Model 2025 EOB and
instructions (new version)
Capitalized defined terms “Out-ofPocket Costs” and your “Total
Drug Costs”.
Added that “other payments” are
“(those made by programs,
organizations, or other plans; “other
payments” may include TrOOP and
non-TrOOP amounts)”.
Revised instructions to plans to
display the amount of an enrollee’s
TrOOP limit instead of the
enrollee’s out-of-pocket costs
threshold.
Revised instructions to plans to
display the amount of an enrollee’s
TrOOP limit instead of the
enrollee’s out-of-pocket costs.
Removed decimal points and cents
when dollar amounts ended in “.00”
Changed curly brackets to square
brackets
Added to Other Payments
explanation: employer or union
health plans and TRICARE. Also
added “some of these payments
may not count towards your Outof-Pocket Costs.”

Type of Reason for
Change1 Change
Rev.
Clarity

Burden
Change2
Yes

Rev.

Clarity

Yes

Rev.

Accuracy

Yes

Rev.

Statutory
change

Yes

Rev.

Readability

Yes

Rev.

Clarity and
consistency
Clarity

Yes

Chart 1A: Removed explanations
of Out-of-Pocket Costs, Total Drug
Costs, and Other Payments

Deleted

Del.

Yes

Chart 2: Removed emphasis and
total drug cost reference in chart.
N/A

Deleted

Del.

Chart 2: Added “year-to-date” to
Out-of-Pocket Costs total
Added to description: employer or
union health plans and TRICARE
Removed from description:
“Payments made for your drugs by
employer or union health plans;
some government-funded programs
(including TRICARE)”
Revised instructions to include
“Drugs you got from a non-network
pharmacy that doesn’t meet our
requirements” if applicable.
Removed references to Coverage
Gap phase in text and charts.
Revised references to Drug

Add

Clarity; Chart
1A does not
include any
amounts that
count toward
TrOOP or
total drug
costs.
Statutory
change
Clarity
Statutory
change
Statutory
change

Yes

Rev.

Clarity

Yes

Rev.

Statutory
change

Yes

Chart 1, 1A, and 2 instructions.

Throughout instructions to plans:
out-of-pocket threshold

Chart 1 and 2 instructions

Throughout
Throughout
Throughout – Other Payments
description: Removed reference to
Medicare’s Coverage Gap
Discount Program

Throughout: revised description of
Out-of-Pocket Costs Include
Throughout: revised description of
“Out-of-Pocket Costs DON’T
include payments made for”

Throughout: revised instructions
for including “Drugs you got from
a non-network pharmacy that
doesn’t meet our requirements”
Throughout

Rev.

Rev.
Rev.

Yes

Yes
Yes

Yes

Model 2023 EOB and
instructions (old version)

Chart 3

Chart 3
Throughout

Chart 3
Chart 3: Stage 2, What Happens
Next?

Chart 3 for enrollees who are in the
coverage gap stage
Chart 3 for enrollees with partial
LIS
Chart 3
Throughout

Chart 4
Important things to know about
your drug coverage
Exhibits

Exbibit B, Example 2

Exhibits
Exhibit B, Example 4
Exhibit B, Examples 5 and 6

Model 2025 EOB and
instructions (new version)
Payment Stages as having 3, not 4,
stages
Added to description of You’re in
Stage 1: “The deductible doesn’t
apply to covered insulin products
and most adult Part D vaccines,
including shingles, tetanus and
travel vaccines.”
Replaced “initial coverage limit”
with “TrOOP limit”
Added to the description of
Catastrophic Coverage that covered
drugs are “covered Part D drugs.”
Replaced “total drug costs” with
“Out-of-Pocket Costs”
Revised What Happens Next? Text
box reference to TrOOP and
Catastrophic Coverage: “Once you
have an additional $[insert amount
needed in additional TrOOP to
meet the TrOOP limit] in Out-ofPocket Costs, you move to the next
payment stage (Stage 3:
Catastrophic Coverage).”
Deleted

Type of Reason for
Change1 Change

Burden
Change2

Add

Statutory
change

Yes

Rev.

Yes

Rev.

Statutory
change
Clarity

Rev.

Clarity

Yes

Rev.

Statutory
change

Yes

Del.

Yes

Deleted

Del.

Replaced “initial coverage limit”
with “TrOOP limit”
Revised misspellings, punctuation,
and capitalization where there were
errors
Replaced ampersand with “and”
Replaced “Chapter 7” with “[MAPD insert: Chapter 9.] [PDP insert:
Chapter 7.]”
Added that all examples use 2024
benefit parameters where 2025
benefit parameters are not yet
available and will be updated in the
final version.
Clarified that Example 2 depicts the
initial coverage stage for an
enrollee with LIS with payments
from plan and from Extra Help or
from another organization
Updated fictional cost and payment
amounts
Changed “his/her” to “their”
Revised Examples 5 to reflect an
enrollee without LIS and Example
6 to reflect an enrollee with LIS.

Rev.
Rev.

Statutory
change
Statutory
change
Statutory
change
Accuracy

Rev.
Rev.

Consistency
Accuracy

Yes
Yes

Rev.

Clarity

No

Rev.

Clarity

No

Rev.

Clarity

No

Rev.
Rev.

Clarity
Clarity

No
No

Yes

Yes
Yes
Yes

Model 2023 EOB and
instructions (old version)

Exhibit C

Exhibit C, Example 5

Exhibit D
Exhibit G

Model 2025 EOB and
instructions (new version)
Removed Worker’s Compensation
from Example 6.
Removed examples of charts
depicting limited gap coverage, no
additional gap coverage, LIS
enrollees with a deductible, and
coverage gap.
Revised Example 5 to reflect a
brand-name/tier level only
deductible
Replaced “consumer” with
“enrollee”
Added cover sheet with
instructions.

Type of Reason for
Change1 Change

Burden
Change2

Del.

Accuracy

No

Rev.

Usefulness

No

Rev.

Consistency

No

Add

Clarity

No

Model 2025 EOB and
instructions (new version)
Added that Medicare Prescription
Payment Plan (MPPP) participants
will receive a separate monthly
billing statement, and amounts
shown in the EOB might differ
from what an enrollee paid. Added
that enrollees can visit
Medicare.gov for information about
the MPPP.
Added that MPPP can help
enrollees manage drug costs by
spreading them out during the year
as monthly payments. Added that
the program is available to anyone
with Medicare Part D and can be
especially helpful to people with
high cost sharing earlier in the plan
year. Added that enrollees can visit
Medicare.gov for information about
the MPPP.
Added that plans are permitted to
eliminate empty spaces between
sections and/or widen text boxes
and columns to save space.
Added that plans may display
EOBs in portrait or landscape
orientation.
Clarified that plans must include
the following information as a
footer on every page excluding the

Type of Reason for
Change3 Change
Add
Statutory
change

Burden
Change4
Yes

Add

Statutory
change

Yes

Add

Clarity

No

Add

Clarity

No

Add

Clarity

No

30-Day PRA Package
Model 2023 EOB and
instructions (old version)
Instructions and Exhibits A, B, and
G: Cover Page, Charts 1 and 2

Instructions and Exhibits F and G:
Important Information

Instructions

Instructions

Instructions

3

Types of Change: Rev. = Revision, Del. = Deletion, Add = Addition
We estimate the changes to the Part D Model EOB, overall, will increase the one-time burden for a business operations specialist to
program the model template into plan systems. See sections 12 and 15 of the Supporting Statement for detailed discussion.
4

Model 2023 EOB and
instructions (old version)

Instructions

Instructions

Instructions

Instructions, Exhibit A

Instructions
Instructions, Exhibits B and G:
Chart 1
Instructions, Exhibits B and G:
Chart 1, You Paid definition
Instructions, Exhibits B and G:
Charts 1 and 2

Instructions: Chart 2

Instructions, Exhibits B and G:
Chart 2
Instructions, Exhibits B and G:
Chart 2, Out-of-Pocket Costs
Include definition
Instructions, Exhibits B and G:
Chart 2

Model 2025 EOB and
instructions (new version)
cover page (where the information
is already included): the plan name,
plan phone number, including the
TTY number and a statement that
calls to the plan are free, and plan
URL.
Added that costs included may be
displayed with or without decimals
and cents (e.g. $0.00).
Clarified that the Drug Price
column shows the negotiated price
as defined at § 423.100.
Added that if no lower-cost
therapeutically equivalent drug is
available, plans may enter “No
lower-cost alternative drug is
available.”
Clarified that plans should use the
return address that meets the plan’s
business needs.
Replaced fictional costs with “$X.”
Revised Drug Price definition to
reference “payments made by you,
your plan, and others.”
Removed “out-of-pocket”

Type of Reason for
Change3 Change

Burden
Change4

Add

Clarity

No

Rev.

Clarity

No

Add

Clarity

No

Add

Clarity

No

Rev.
Rev.

Readability
Clarity

No
Yes

Del.

Readability

Yes

Revised Other Payments definition
to include any payments not in the
“You Paid” and “Plan Paid”
columns, such as those made by
Extra Help from Medicare,
employer or union health plans,
TRICARE, Indian Health Service,
AIDS drug assistance programs,
Manufacturer Discount Program,
charities, and State Pharmaceutical
Assistance Programs (SPAPs).
Added optional note that plans can
include as a bullet under Out-ofPocket Costs include:
“Supplemental drug benefits paid
by your plan.”
Inserted You Paid and Plan Paid
definitions
Removed “other”

Rev.

Statutory
Change

Yes

Add

Accuracy

No

Add

Clarity

Yes

Del.

Readability

Yes

Added Manufacturer Discount
Program and Selected Drug
Subsidy to description of “Out-ofPocket Costs DON’T Include
Payments Made for.”

Add

Statutory
Change

Yes