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Starting in 2025, Part
D beneficiaries will be protected by a $2,000 OOP spending cap. Part D
plans will also be required to allow enrollees to spread their OOP costs
over the course of the plan year, also known as “OOP smoothing.” Avalere
projected that 2.6 million non-LIS beneficiaries will have OOP spending
above the $2,000 cap and 4.2 million will hit $1,500 in OOP spending in
2025.
Avalere analyzed the circumstances under which enrollees
would incur most of their OOP costs in the last few months of the plan
year, once the smoothing program is in place. Among those reaching
greater than $1,500 in OOP spending, around 20,000 enrollees are
projected to have large OOP spending (i.e., more than $1,250) in the last
three months of the year. Greater shares of racial/ethnic minority
groups, including Asian, Black and Hispanic beneficiaries, are projected
to face such circumstances.
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