Inflation Reduction Act (IRA) Implementation

Medicare


Signed into law in 2022, the Inflation Reduction Act (IRA) ushered in Medicare prescription drug pricing reforms and imposed caps on out-of-pocket expenses for Part D beneficiaries. While much discussion and analysis has focused on how the IRA will impact Medicare beneficiaries, Part D plans, and government spending, the impact of the legislation will extend to stakeholders across the U.S. health care industry.

Many questions remain about the implementation of this law, which will be done through agency guidance, program instruction, agreements between CMS and drug manufacturers, and notice-and-comment rulemaking.

IRA Implementation milestones:

  • 2025
    • January 29, 2025: CMS issued the first press release of the second Trump Administration indicating that CMS intends to continue the IRA’s Medicare Drug Price Negotiation Program to lower prescription drug costs for Americans. 
    • June 1, 2025: Deadline for CMS to issue initial written offers for the first round of drug negotiations 
  • 2026: The first round of price negotiations will occur, with 10 Part D drugs selected for the initial negotiation cycle.
  • 2027: Negotiated prices for the first 10 Part D drugs will take effect.
  • 2028: Negotiations will expand to include both Part D and Part B drugs, with 15 additional drugs selected for negotiation.

Stakeholders continue to navigate the interplay between patient access, formularies, and manufacturer considerations. These changes impact the liability of beneficiaries, manufacturers, and plans—adding a new dynamic to the already-complex interaction between these groups.

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