ACAP Comment Letter on Medicare Part D MPPP Guidance

On September 20, ACAP submitted its comment letter to CMS on the Maximum Monthly Cap on Cost-Sharing Payments Under Prescription Drug Plans: Draft Part One Guidance on Select Topics, Implementation of Section 1860D-2 of the Social Security Act for 2025.

ACAP fully supports the Medicare Prescription Payment Plan’s (MPPP) overarching goals and in the letter offers recommendations to improve the implementation and operation of this program for D-SNPs and the dually eligible individuals they serve.

These recommendations include comments on the following topics:

  • Considerations for LIS and Dually Eligible Beneficiaries
  • Operational Considerations
  • Beneficiary Education and Enrollment
  • Billing and Collection
  • Timeline of Guidance Releases & Implementation


Read the comments in detail, with additional background, via the link to the right.