More Ways to Improve Medicare Part D Extra Help for Low-Income Older Adults

Everyone deserves access to medication. People enrolled in the Part D Extra Help program (also called the Low-Income Subsidy or LIS) qualify for subsidies to cover some of their out-of-pocket prescription drug costs.

Ensuring access to affordable drugs for LIS enrollees is an important way to address health inequities. LIS enrollees are more likely, for instance, to have disabilities and/or identify as Black or Hispanic.

Being enrolled in LIS doesn’t mean that you don’t pay a Part D premium. The average LIS enrollee receiving the full subsidy in 2020 and 2021 paid on average $60 and $54 per year in premiums.¹ Luckily, LIS enrollees shopping on the Medicare.gov Plan Finder can find LIS benchmark plans with $0 premiums or enhanced Part D plans with premiums that are less than $10 a month.

Yet the program is not meeting everyone's needs. Many LIS enrollees may discover that not one of these two types of plans in their state covers all their prescription drugs or has their nearby pharmacies in network. The number of standalone prescription drug plans—those that are not part of a Medicare Advantage plan—and the number of $0 premium LIS benchmark plans has been decreasing in recent years. The reduction in the number of standalone Part D prescription drug plans and LIS benchmark plans is a concerning trend and one that may continue. This makes it less likely that a LIS enrollee can find an appropriate plan that both includes their medications and a nearby pharmacy and has an affordable premium.

On May 7, 2024, NCOA wrote a letter (co-signed by 27 other beneficiary and disease-focused  organizations) to CMS Administrator Chaquita Brooks-LaSure that asks CMS to increase the number of $0 premium LIS benchmark plans that a LIS beneficiary can choose from. We asked CMS to do so to ensure that all low-income Part D Extra Help enrollees can access their needed medications and preferred pharmacies while not having to pay a burdensome premium.

NCOA isn’t just focusing on LIS benchmark plans in the letter, but we’re asking for some LIS changes that are somewhat adjacent. The second topic is “intelligent assignment” (also known as “beneficiary-focused assignment”), or asking CMS to be more careful when automatically assigning beneficiaries to $0 premium LIS benchmark plans.

We asked CMS to ensure that LIS enrollees who are automatically assigned to $0 LIS benchmark plans cover needed medications and have nearby pharmacies in network.

NCOA also asked CMS to test whether sending a notice to all LIS enrollees paying premiums would change beneficiary behavior. The notice, which already exists and goes out to a smaller subset of this population, encourages enrollees to ensure that their plan is affordable and covers needed medications and has their local pharmacy in network.

In February 2023, NCOA and the PAN Foundation wrote a letter (co-signed by 68 other advocacy organizations) to CMS that included the latter two recommendations along with many others related to the Part D Extra Help program. We used the May 2024 letter to remind CMS of these two remaining requests.

On May 2, 2024, NCOA, Justice in Aging, Medicare Rights Center, and the Patient Access Network (PAN) Foundation met with CMS to discuss intelligent assignment and the audience the Chooser’s Notice is sent to. CMS said it is very interested in further exploring intelligent assignment. Yet CMS said it is focused right now on making the Chooser’s Notice more impactful for the current audience it is sent to. NCOA and the PAN Foundation have since told CMS that they are very interested in working with CMS to make the Chooser’s Notice more effective.