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. StopAfib.org, 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 AgingResearch.org/Project-Loop.