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49 Organizations to CMS: Enact Protections, Education for Medicare Beneficiaries Related to Part D Redesign

Published June 5, 2023

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The Alliance for Aging Research along with 48 additional organizations submitted a letter to Meena Seshamani, MD, PhD, Deputy Administrator and Director of the Center for Medicare at the Centers for Medicare & Medicaid Services (CMS), offering feedback on the forthcoming implementation of the Inflation Reduction Act’s (IRA) provisions related to the Medicare Part D redesign. These provisions include the smoothing flexibility that allows beneficiaries to spread out their costs throughout the year, and the ability for Medicare to negotiate drug prices with manufacturers.

The letter highlights the need for the Medicare Program to enact significant protections for beneficiaries and recommends the development of effective communication strategies to educate beneficiaries about these new provisions, including working with various stakeholders to create standardized educational resources that clearly explain the benefit, enrollment processes, and payment expectations. Additionally, it advocates for the establishment of clear guidelines and criteria for disqualification from cost smoothing, a transparent appeals process, and a minimum grace period for late payments.

The groups also note that CMS must monitor and protect against potential unintended consequences due to a broader Part D redesign, including clinically inappropriate use of utilization management techniques. The letter cautions against potential limitations on patient access to care and adverse outcomes resulting from insurers’ increased utilization management techniques, and recommends monitoring the techniques’ impact on beneficiaries.

Download a PDF of the full letter.

The full list of signatories includes:

  1. ADAP Advocacy Association
  2. Alliance for Aging Research
  3. Alliance for Patient Access
  4. ALS Association
  5. American Association of Kidney Patients
  6. American Cancer Society Cancer Action Network
  7. American Kidney Fund
  8. Autistic People of Color Fund
  9. Autistic People of Color Fund
  10. Autistic Women & Nonbinary Network
  11. Autoimmune Association
  12. Cancer Support Community
  13. CancerCare
  14. CLL Society
  15. Coalition of Wisconsin Aging and Health Groups
  16. Community Access National Network
  17. Derma Care Access Network
  18. Global Healthy Living Foundation
  19. Global Liver Institute
  20. Hawai’i Parkinson Association
  21. Haystack Project
  22. Headache & Migraine Policy Forum
  23. HealthyWomen
  24. ICAN, International Cancer Advocacy Network
  25. International Pemphigus Pemphigoid Foundation
  26. JDRF
  27. LUNGevity Foundation
  28. Lupus and Allied Diseases Association
  29. Lupus Foundation of America
  30. National Health Council
  31. National Organization for Rare Disorders
  32. National Psoriasis Foundation
  33. Neuropathy Action Foundation
  34. Noah Homes
  35. Organic Acidemia Association
  36. Partnership to Advance Cardiovascular Health
  37. Partnership to Fight Chronic Disease
  38. PlusInc
  39. RASopathies Network
  40. Red Hot Mamas North America Inc
  41. RetireSafe
  42. Second Wind Dreams
  43., American Foundation for Women’s Health
  44. The Asthma and Allergy Foundation of America
  45. The Headache and Migraine Policy Forum
  46. The Mended Hearts, Inc.
  47. Triage Cancer
  48. TSC Alliance
  49. U.S. Pain Foundation

To learn more about collective efforts to lower out-of-pocket costs related to Medicare Part D, visit

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