Project 2025 Tracker / What’s done, what’s next

14. Department of Health and Human Services · Notable · Needs Congress

Eliminate the Part D coverage gap and shift catastrophic costs to manufacturers

Not started

465 14. Department of Health and Human Services

“Other reforms should include eliminating the coverage gap in Part D, reducing the government share in the catastrophic tier, and requiring manufacturers to bear a larger share.”

What has happened

  1. Not started

    Already true before the evidence window: the Inflation Reduction Act's Part D redesign (§ 11201 of Public Law 117-169) took effect on 2025-01-01, nineteen days before the window opens. It eliminated the coverage gap phase outright, leaving a three-phase benefit; it cut the government's reinsurance share in the catastrophic phase from 80 percent to 20 percent for applicable drugs; and it replaced the Coverage Gap Discount Program with the Manufacturer Discount Program, which makes manufacturers liable for a discount in the catastrophic phase for the first time. CMS restates all three in the CY 2027 Advance Notice: "Beginning in CY 2025, the IRA eliminated the coverage gap phase" and "The Coverage Gap Discount Program sunset effective January 1, 2025, and was replaced by the new Manufacturer Discount Program." Nothing inside the window advances or reverses it, so the Status stays `not-started` and the flag records that the ask was already satisfied — by the very statute the same page of the Mandate asks Congress to repeal.

Research log

What was searched, and what didn’t count as evidence

Research notes

  • This is the third Already true item in Chapter 14, after #1314 and #1344, and the only one where the satisfying instrument is the law the Mandate elsewhere wants repealed (#1270).
  • Sources: CY 2027 Advance Notice, cms.gov, 2026-01-26, Part D benefit parameters section, read at https://www.cms.gov/files/document/2027-advance-notice.pdf. Queries: a search of bill titles among those we keep and search, from congress.gov, for “coverage gap” → 1 (a contraception bill); the public laws we keep and search → nothing on Part D benefit structure.
  • Confirmed 2026-09-01; the Already true flag is kept. The ask is to eliminate something, not to preserve or continue it, so the flag is available, and all three limbs - the coverage gap, the government’s catastrophic share, the manufacturers’ share - were satisfied on 2025-01-01, nineteen days before the window opened, so nothing remains outstanding. That the satisfying instrument is the statute the Mandate elsewhere wants repealed is a fact for the note, not a reason to withhold the flag.
  • Checked 2026-09-06: the flag stands. The satisfying instrument is statutory - IRA § 11201, effective 2025-01-01 - so the object could only be undone by Congress, and no 119th-Congress law among the public laws we keep and search amends the Part D benefit redesign (searched again 2026-09-06). CMS’s own in-window documents restate the three-phase benefit and the Manufacturer Discount Program as current. That the same page of the Mandate asks Congress to repeal the statute that satisfied this ask (#1270) is a standing irony, not a reversal: the repeal has not happened.
Action
eliminate
Object
Medicare Part D coverage gap and catastrophic tier
ID
1271