Transition from CGDP to the new Part D Manufacturer Discount Program

In our previous post, we covered the final guidance that CMS published on November 17, 2023. CMS clarified the details of the transition from the Coverage Gap Discount Program (CGDP) to the new Part D Manufacturer Discount Program (MDP) under the IRA.

The IRA sunsets CGDP as of January 1, 2025, and terminates all CGDP Agreements effective the same day. However, manufacturers' responsibilities under these agreements continue to apply with respect to drugs dispensed prior to January 1, 2025. While manufacturers will not incur any new liabilities under CGDP for dates of service after December 31, 2024, CGDP invoicing will continue through the end of 2028 to allow for prescription drug event (PDE) submission run-out. 

CMS expects the final Coverage Gap Discount Program manufacturer invoice to be distributed by April 30, 2028.

The statutory deadline to enter the Part D Manufacturer Discount Program agreement for 2025 is March 1, 2024. A manufacturer that wishes to do so would be well advised to submit ownership information to CMS - a required step of the process - by December 8 December 15, 2023*. CMS will provide manufacturers who do so (even before executing the MDP agreement) with preliminary, non-binding information regarding their eligibility for the discount phase-ins that we discussed in the previous blog post


CMS extended the deadline to submit ownership information to the Health Plan Management System (HPMS) to 11:59 p.m. PST on December 15, 2023.

Published on Dec. 1, 2023 by Sergei Krupenin

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