60-Day Comment Response

Commenters

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Common Theme

Independence Blue Health

Blue Cross Blue Shield of Tennessee

Tamaron Johnson

Primewest Health

BCBS of MN

CVS Health

Alliance for Aging Research/PAN Foundation

Ucare

Kaiser Permanente

Eli Lilly

Biotechnology Innovation Organization

BCBS Association

MAPRx Coalition

PhRMA

Medicare Rights Center

Summary of Comment

Proposed Reponses

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General Comments

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Several commenters expressed appreciation for CMS’s efforts to improve beneficiary communications, including enhancements to clarity, readability, and accessibility of the model documents. Commenters commended the addition of the Notice of Participation Renewal and the additional translated versions of the Likely to Benefit Notice. Commenters encouraged further expansion of translated materials across all model documents.

CMS thanks the commenters for their support.

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A commenter expressed concern that CMS's burden estimates for information collections are too narrow and exclude significant one-time implementation costs including system integration, template adaptation, and staff training. The commenter recommended CMS adopt a dual-component framework that separates initial implementation burdens from ongoing operational costs.

In Supporting Statement A, CMS has accounted for one-time implementation costs associated with new model materials, specifically the notice of participation renewal. This includes discrete burden estimates for “MPPP Auto-Renewal Development (One-Time Burden)” and “MPPP Set Up Systems for Auto-Renewal (One-Time Burden)” and is separate from annual burden estimates for distribution of the model materials. CMS believes these estimates sufficiently address the commenter's concerns regarding initial implementation costs. CMS will continue to monitor operational impacts and consider additional refinements to burden estimates in future reviews of this information collection request package.

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A commenter raised concerns about the use of the model documents for Dual-Eligible Special Needs Plans (D-SNPs). Specifically, the commenter noted that Exhibits 3, 4, 6, and 7 contain language about premium payments and resources for cost assistance that may not apply to D-SNP enrollees who do not pay premiums and are already enrolled in Medicaid. The commenter expressed concern that this language may confuse D-SNP members and urged CMS to exempt D-SNP plans from the Medicare Prescription Payment Plan entirely.

CMS recognizes commenters' concerns about those who are less likely to benefit from the program, including D-SNP enrollees, receiving program materials. As noted in the April 2025 Final Rule, “Medicare and Medicaid Programs; Contract Year 2026 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicare Cost Plan Program, and Programs of All-Inclusive Care for the Elderly,” CMS does not expect Part D plans that exclusively charge $0 cost sharing for covered Part D drugs to all plan enrollees to offer the Medicare Prescription Payment Plan because there is no practical application for the Medicare Prescription Payment Plan in Part D plans that do not charge cost sharing for covered Part D drugs. While CMS recognizes that Part D enrollees with low cost sharing may be less likely to benefit from the Medicare Prescription Payment Plan, under section 1860D-2(b)(2)(E)(i) of the Act, Part D plan sponsors must provide the option to participate in the Medicare Prescription Payment Plan to all Part D enrollees, including subsidy eligible individuals as defined in paragraph (3)(A) of section 1860D-14(a) of the Act. Because the statute explicitly requires that the Medicare Prescription Payment Plan be offered to subsidy-eligible individuals and because such beneficiaries could determine that they would benefit from the Medicare Prescription Payment Plan under certain circumstances, D-SNPs that offer nominal cost sharing are required to offer the Medicare Prescription Payment Plan to their enrollees. CMS continues to encourage Part D plan sponsors to provide support tailored to beneficiaries' unique situation(s) and clearly communicate to enrollees when it appears that they are less likely to benefit from the program (for example, enrollees with low-to-moderate recurring out-of-pocket drug costs). As established in §§ 423.2267(c), model materials and content are required materials and content created by CMS as an example of how to convey beneficiary information. If Part D sponsors choose to not use the CMS-developed model notice and develop their own voluntary termination notice, they must include all of the required elements outlined at §§ 423.137. Additionally, we remind the commenter that as stated at 42 CFR § 423.137(m)(1), D-SNPs are exempted from the requirement to provide a Medicare Prescription Payment Plan election request form and additional educational information on the program in a hard copy mailing.

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Several commenters expressed concerns about low enrollment rates and limited public awareness of the Medicare Prescription Payment Plan. Commenters strongly urged CMS to strengthen education and targeted outreach efforts through comprehensive engagement with stakeholders, including healthcare providers, State Health Insurance Assistance Program counselors, patient advocacy organizations, and plans to broaden program awareness by leveraging their trusted relationships with beneficiaries and deep understanding of community needs.

CMS thanks commenters for their feedback and interest in the program and agrees that educating beneficiaries about the program is important for its success. In advance of the implementation of the program on January 1, 2025, CMS developed new educational resources and updated existing Part D materials, such as the Annual Notice of Change (ANOC), Evidence of Coverage (EOC), and Explanation of Benefits (EOB), to inform Part D enrollees about the program. Supporting broad awareness of the Medicare Prescription Payment Plan is also a responsibility of Part D sponsors. To ensure all prospective and current Part D enrollees are aware of the program, CMS requires Part D plan sponsors to conduct outreach and education requirements for the program, as established at 42 CFR § 423.137.

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Several commenters recommended that CMS revise model documents to better reflect key program features and beneficiary protections. Suggestions included clearly stating that the Medicare Prescription Payment Plan is a government program, referencing the annual out-of-pocket cap, explaining the grievance process and grace period, and including references to programs that reduce expenses and cost-saving measures available under Part D, such as the low-income subsidy (LIS), state pharmaceutical assistance programs, charitable assistance programs, and the $35 insulin cap.

CMS thanks commenters for their feedback and agrees that raising awareness of other financial assistance programs, such as Medicare Extra Help, is important to help ensure that eligible Medicare beneficiaries are aware of and able to enroll in the program that best fits their needs. The model notices include a list of additional financial assistance programs, including Extra Help, with a description of the program and a link to learn more. Additionally, CMS requires Part D sponsors to include on their website(s) general information about the LIS program, including an overview of how LIS enrollment, for those who qualify, is likely to be more advantageous than program participation. Additionally, CMS notes that Exhibits 4 and 5 direct enrollees to contact their plan if they think they’ve received the notice in error and also informs them of their right to appeal an involuntary termination through the grievance process.

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A commenter recommended using consistent terminology across exhibits to avoid confusion. The commenter requested clarification on whether the instructions for each exhibit should refer to a “notice” or a “request form.” The commenter also noted that the instructions in Exhibit 4 state that Part D sponsors are strongly encouraged to include the additional fields RxID, Rx Group, RxBin and RxPCN, while the instructions in Exhibit 5 and Exhibit 6 state that Part D sponsors may include those additional fields, and requested that CMS use consistent language across exhibits.

CMS thanks the commenter for their feedback on improving clarity and consistency in terminology across exhibits. CMS has revised language in the instructions for each exhibit to appropriately distinguish between a “notice” and a “request form” depending on the purpose of each document. While Part D sponsors may choose to include 4Rx information (Part D RxID, RxGroup, RxBin, and RxPCN) on the Notice for Failure to Make Payments, Notice of Termination of Participation, and Notice of Voluntary Removal, CMS strongly encourages Part D sponsors to include 4Rx information, including the Medicare Prescription Payment Plan RxBIN and RxPCN on the Notice to Acknowledge Acceptance of Election because enrollees who have just begun participating in the Medicare Prescription Payment Plan are most likely to benefit from having these identifiers available to support accurate processing of processing claims under the Medicare Prescription Payment Plan.

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A few commenters appreciated that several model documents—including the Likely to Benefit Notice, Election Request Form, Notice of Election Approval, and Notice of Participation Renewal—include an upfront, concise overview of the Medicare Prescription Payment Plan. However, a commenter recommended extending this overview to all model documents, including the Notice of Failure to Pay and the Notices of Involuntary and Voluntary Termination, to reduce beneficiary confusion and improve clarity. Commenters also suggested standardizing subject lines, including a “Why am I receiving this?” section, and encouraging use of plan logos to help beneficiaries recognize official communications.

CMS thanks the commenters for their support. CMS has included overviews of the Medicare Prescription Payment Plan in documents where such information is most relevant and beneficial to beneficiaries. The program overview is appropriately included in documents such as Exhibits 1, 2, 3 and 7 because these documents relate to beneficiaries who are either considering enrollment, actively enrolling, or maintaining participation in the program. We believe that including a detailed program overview in Exhibits 4, 5 and 6 would be potentially confusing to beneficiaries. Additionally, the “Instructions” section for each model notice states that plans may include plan-specific information and branding on all notices.

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1.3 – Likely to Benefit Instructions

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A commenter requested clarification whether the OMB control number requirement applies only to Exhibit 1 or to all model communications within the CMS-10882 collection. The commenter noted that Exhibit 1.3 instructions state the OMB control number must be displayed in the lower right corner of the Likely to Benefit Notice and describes it as a "standardized notice," while 42 CFR 423.2267(e) refers to all other notices in the collection as "model communications."

CMS thanks the commenter for their question. The OMB control number requirement applies only to Exhibit 1, because Exhibit 1 is a standardized material that Part D sponsors are required to use in the form and manner provided by CMS. The other Exhibits in this collection are model materials and content, which are required materials and content created by CMS as an example of how to convey beneficiary information. If Part D sponsors choose not to use the CMS-developed model notices and develop their own notices, they must include all of the required elements outlined at §§ 423.137. Part D sponsors can refer to §§ 423.2267(b) and 423.2267(c) for requirements related to the use of model materials and content.

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A commenter recommended that CMS remove the requirement to include the Part D plan’s telephone number beneath the logo in the Likely to Benefit Notice, citing potential confusion due to varying contact numbers across plan types. Another commenter requested clarification on whether the name, address, and phone number are only required if the logo is included, noting that the current instructions are unclear.

CMS thanks the commenters for their feedback. CMS clarifies that the name, address, and telephone number of the Part D plan are only required beneath the logo if they are not incorporated within the logo itself. As stated in the instructions for the Likely to Benefit Notice, inclusion of the logo is optional when distributed outside of the pharmacy point of sale (POS) process and is not required when distributed by the pharmacy.

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1 – Likely to Benefit Notice

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A few commenters expressed support for CMS’s efforts to streamline the Likely to Benefit Notice to a single page. Several commenters recommended that CMS reinstate content from the 2025 version of the Likely to Benefit Notice to improve beneficiary understanding and reduce unnecessary call volume for plans. Commenters also recommended restoring a bulleted list of scenarios where the Medicare Prescription Payment Plan may not be beneficial to a given individual. Additional suggestions included referencing the annual out-of-pocket cap, providing example calculations, and clarifying that MPPP involves no interest or fees.

CMS thanks the commenters for their support. CMS has streamlined the Likely to Benefit Notice to one page to reduce operational burden for pharmacies. The Likely to Benefit Notice is intended to introduce beneficiaries to the Medicare Prescription Payment Plan program and direct them to other resources for additional information, including the Medicare Prescription Payment Plan page on Medicare.gov which has information on the mechanics of the calculations and a tool to help beneficiaries assess whether they should participate.

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Several commenters suggested edits to the materials to improve readability and plain language and provide additional information.

CMS thanks the commenters for their careful review of the Likely to Benefit Notice and shares the goal of making model materials clear, concise, and easy to understand. The language in the model materials reflects the feedback received during consumer testing with a representative sample of Medicare Part D enrollees.

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A commenter recommended that CMS reinstate the previous text-based explanation of how to sign up for the Medicare Prescription Payment Plan without the box outline to avoid creating unnecessary programming complexity for plan sponsors without providing additional benefit. Another commenter recommended that CMS enhance the formatting of the enrollment prompt at the bottom of the Likely to Benefit Notice by bolding the box outline for visual consistency with other exhibits and adding the word “Important:” to emphasize the need for beneficiary action.

CMS thanks the commenters for their feedback. The intent of the boxed format at the bottom of the Likely to Benefit Notice was to provide a visually distinct and accessible prompt that encourages enrollee action. In response to the comment that the revised notice with the boxed format would create “unnecessary programming complexity,” CMS has revised the notice to remove the box and instead bolded the entire statement to reinforce the prompt for enrollee action.

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A commenter recommended that CMS provide Part D sponsors with flexibility to use either the currently approved version of Exhibit 1 notice or the updated version for the 2026 plan year, citing the need for additional lead time to incorporate changes into beneficiary materials.

CMS is working to provide materials in a timely manner to support implementation of revised materials in advance of the date organizations are permitted to begin marketing their CY 2026 plans.

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Exhibit 2 – Participation Request Form

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Several commenters suggested edits to the materials to improve readability and consistency or provide additional clarification, such as modifying the automatic renewal language to specify that renewal only applies if the beneficiary remains in the same health plan.

CMS thanks the commenter for their careful review of the Participation Request Form and has made revisions to improve readability and clarity throughout the document.

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A few commenters suggested that CMS include information on the timeline for plan sponsors to respond to election requests.

CMS thanks the commenters for their suggestion and declines to include this information in the model Participation Request Form, in order to keep model materials concise and easy to understand. The Participation Request Form provides enrollees with plan contact information for questions and additional assistance.

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Several commenters requested that CMS consider modifying the election request form to include a field allowing the beneficiary to select whether they would like their election request to be effective for the current plan year or the upcoming plan year. Commenters noted that adding a new field noting which plan year the election request applies will ensure participation requests received in the last quarter of the year are appropriately attributed to the correct plan year and will help plan sponsors process requests within the correct timelines.

CMS appreciates commenters’ feedback on the Participation Request Form. Exhibit 2 has been updated to include a radio selection field where beneficiaries can indicate whether their participation request should be effective for the current plan year or the upcoming plan year.

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Exhibit 3 – Notice of Election Approval

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A couple of commenters suggested edits to the materials to improve readability and plain language and include additional information, such as information on how a bill can be paid and more information about grace periods and beneficiary protections. A commenter requested that CMS emphasize that enrollees are not required to pay the remaining balance immediately upon disenrollment.

CMS thanks the commenters for their careful review of the Notice to Acknowledge Acceptance of Election. Exhibit 3 informs enrollees of their right to appeal through the grievance process. Additionally, CMS notes that Exhibits 5 and 6 state that enrollees who leave the Medicare Prescription Payment Plan must pay any outstanding balances but can choose to pay their balance all at once or be billed monthly.

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Exhibit 4 – Notice of Failure to Pay

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A couple of commenters suggested edits to the materials to improve readability, plan language, and consistency across model materials. One commenter recommended that CMS encourage plans to send the most recent monthly billing statement with the notice to help beneficiaries understand their drug costs and responsibilities.

CMS thanks commenters for their careful review of the Notice for Failure to Make Payments and has made revisions to ensure consistency and clarity across materials in this information collection package. CMS also notes that Exhibit 4 includes a statement of the specific amount owed by the recipient.

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Exhibit 5 – Notice of Involuntary Termination

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A couple of commenters suggested edits to the materials to improve readability and plain language and clarify that beneficiaries involuntarily disenrolled from the Medicare Prescription Payment Plan will only be responsible for their out-of-pocket share of drug costs.

CMS thanks commenters for their careful review of the Notice for Failure to Make Payments and has made revisions to ensure consistency and clarity across materials in this information collection package. CMS also notes that Exhibit 4 includes a statement of the specific amount owed by the recipient. CMS thanks the commenters for their careful review of the Notice for Failure to Make Payments – Notification of Termination of Participation. CMS does not believe additional clarification is necessary, because as noted at 42 CFR § 423.137(b)(1), out-of-pocket costs for the Medicare Prescription Payment Plan refers to the cost sharing amount the Part D enrollee is directly responsible for paying. The current language is consistent with this definition and accurately describes the enrollee’s financial responsibility following disenrollment from the Medicare Prescription Payment Plan.

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Exhibit 6 – Notice of Voluntary Termination

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A couple of commenters suggested edits to the materials to improve readability and plain language and provide additional information such as the amount owed, the amount already applied toward their out-of-pocket costs , or an explanation of the consequences of not paying the remaining balance.

CMS thanks the commenters for their feedback. CMS does not believe additional information is necessary as exhibit 6 states “You’re required to pay the amount you owe, but you won’t pay any interest or fees, even if your payment is late. You can choose to pay that amount all at once or be billed monthly. Contact [plan name] if you have questions about paying your balance.”

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Exhibit 7 – Part D Sponsor of Participation Renewal in the Medicare Prescription Payment Plan

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Several commenters suggested edits to provide clarifications and additional information on the program, such as reminders that there is no cost to participate, no interest or fees, and that the beneficiary remains financially responsible for medication costs through monthly payments. Commenters also requested that CMS provide a more detailed list of programs available to help lower costs, to be consistent with other notices. One commenter suggested removing the word “still” from the sentence “You’ll still be in [plan name] for [upcoming year]” to avoid confusion in cases where plan names change despite continued enrollment.

CMS thanks the commenters for their feedback. Exhibit 7 is intended to alert Medicare Prescription Payment Plan participants that their participation in the program will automatically renew and provide information on the process for opting out of the program. Part D sponsors may insert a link to their Medicare Prescription Payment Plan website or customer service phone number to direct enrollees who may have additional questions about the program. Additionally, CMS declines to remove "still" from the renewal notice language because it clarifies that beneficiaries maintain their plan enrollment even when opting out of the payment option.

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Out-of-Scope

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CMS received a number of comments that are out of scope for this ICR package, including comments related to other CMS outreach and educational efforts, data collection, monitoring, and public reporting for the Medicare Prescription Payment Plan, pharmacy point-of-sale election, timing of voluntary termination effectuation, and setting the likely to benefit threshold.

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