The Centers for Medicare & Medicaid Services (CMS) Innovation Center is in the process of developing the Medicare $2 Drug List (M2DL) Model. This would allow Part D plan sponsors to offer a standardized list of generic drugs for a copayment of $2 or less for a month’s supply that would not be subject to prior authorization, quantity limits, or other utilization management restrictions.
In October 2024, CMS included a sample $2 drug list in a Request for Information (RFI) about the model. The sample $2 Drug List shared in the RFI represents a starting point for the Innovation Center’s development of the M2DL Model which, pending development, could start as early as January 2027.
In this report, we use CMS’ sample $2 drug list to present results from simulating the M2DL Model across all Part D plans that would be eligible to participate in the M2DL Model. We illustrate how overall enrollee cost sharing would change under this model. While the M2DL Model would apply to both LIS and non-LIS enrollees, we focus our analysis on the non-LIS population, as this is where OOP spending would mostly be affected.
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