Catastrophic Coverage is paid by a combination of your Medicare Part D plan, the government and if your purchase was a brand-name drug, then a portion is paid by the drug manufacturer. Once you enter Catastrophic Coverage, you do not pay anything for your formulary drugs for the remainder of the year.
In 2025, the Inflation Reduction Act (IRA) eliminated the Coverage Gap and extended the Initial
Coverage phase until a person has spent $2,000 out-of-pocket for Part D
formulary drugs. The $2,000 represents the prescription drug maximum out-of-pocket spending limit (
RxMOOP).
And as stated above, when a person reaches the RxMOOP (
$2,100 in 2026), the plan member enters Catastrophic Coverage and will not have any additional costs for Part D
formulary drugs for the remainder of the year.
Also in 2025, the IRA changed the percentage of the drug
costs allocated to the brand-name drug manufacturer, Medicare Part D
plan, and the federal government, see example table below.
Beginning January 1, 2025
When you purchase a Part D formulary medication
with a $100 retail cost |
|
Brand-name
Drug
Retail Cost |
You Pay |
Your Medicare
drug plan pays |
Pharma
Mfgr. pays |
Federal
Govern.
pays |
Amount counted
toward your
RxMOOP
Threshold
|
Initial Deductible (if any)
|
$100 |
$100 |
$0 |
$0 |
$0 |
$100 |
Initial Coverage phase - brand-drugs * |
$100 |
$25 |
$65 |
$10** |
$0 |
$25 |
Initial Coverage phase - generic-drugs * |
$100 |
$25 |
$75 |
$0 |
$0 |
$25 |
Catastrophic Coverage (brand drug) **** |
$100 |
$0 |
$60 |
$20 |
$20 |
n/a |
Catastrophic Coverage (generic drug) **** |
$100 |
$0 |
$60 |
$0 |
$40 |
n/a |
* 25% coinsurance or cost-sharing until you reach the $2,000 RxMOOP, then
your Part D formulary drug costs are $0 for the remainder of the year.
** The 10% brand-name drug manufacturer portion paid in the 2025
Initial Coverage phase (after the standard deductible)
does not apply
toward the $2,000 TrOOP threshold
(https://www.cms.gov/files/document/manufacturer-discount-program-final-guidance.pdf).
**** Starting in 2025, the Coverage Gap (or Donut Hole) no longer
exists for plan members. A plan member will stay in the Initial Coverage
phase until exceeding the plan's $2,000 out-of-pocket spending
threshold and then enter Catastrophic Coverage where for the remainder of the
year, the person will have no out-of-pocket costs for formulary
drugs. As noted below, the $2,000 out-of-pocket threshold or RxMOOP can
change every year.
Medicare Part D coverage 2025 and beyond
Question: Can the $2,000 RxMOOP change every year?
Yes. Like other Medicare Part D plan parameters, the annual
$2,000 RxMOOP can (and probably will) change every year. Currently, the
Catastrophic Coverage threshold (or RxMOOP)
is predicted to decrease over time.
Year |
Catastrophic threshold
(RxMOOP)
|
2024
|
$8,000 |
2025
|
$2,000 |
2026 |
$2,100 |
2027 |
$2,050 |
2028 |
$2,000 |
2029 |
$1,950 |
Tip: Need some help planning your spending throughout the phases of your Medicare drug coverage?
To help you visualize the phases of your Medicare Part D prescription drug plan coverage, we have a Out-of-Pocket Cost Calculator or
PDP-Planner.com
online illustrating the changes in your monthly estimated costs based
on the established annual standard Medicare Part D plan limits mentioned
above.
A bit of history...
Prior to plan year 2024, Medicare Part D plan members who had high medication costs would pay roughly 5% of the formulary drug's retail cost during the Catastrophic Coverage phase.
Of the remaining 95% of the total retail drug cost, 80% of the cost was paid by the federal government or Medicare’s reinsurance subsidy, 15% of the retail drug cost was
paid by the Medicare prescription drug plan (Medicare Part D plan or Medicare Advantage plan).
So, as illustrated in the example below, if you reached the 2023 Catastrophic Coverage phase and buy a brand-name formulary drug with a $300 retail cost, you paid $15 for the drug, the federal government paid $240, and the Medicare Part D prescription drug plan paid $45.
In 2024, the Inflation Reduction Act (IRA) eliminated beneficiary cost-sharing in the Catastrophic Coverage phase.
A Medicare Part D plan member did not have any out-of-pocket costs after reaching the plan's total out-of-pocket threshold (
TrOOP) of $8,000. Therefore, the
2024 TrOOP became the prescription drug maximum out-of-pocket spending threshold (
RxMOOP).
Below is a chart showing how example formulary drug purchases were paid
throughout your Medicare Part D plan coverage -- using the
CMS defined standard benefit Medicare Part D plan with a fixed 25% coinsurance for calculating cost-sharing.
Beginning January 1, 2024
When you purchase a Part D formulary medication
with a $100 retail cost |
|
Retail Cost |
You Pay |
Your Medicare
drug plan pays |
Pharma
Mfgr. pays |
Federal
Govern.
pays |
Amount counted
toward your TrOOP
Threshold
|
Initial Deductible |
$100 |
$100 |
$0 |
$0 |
$0 |
$100 |
Initial Coverage phase * |
$100 |
$25 |
$75 |
$0 |
$0 |
$25 |
Coverage Gap - brand-name ** |
$100 |
$25 |
$5 |
$70 |
$0 |
$95 |
Coverage Gap - generic *** |
$100 |
$25 |
$75 |
$0 |
$0 |
$25 |
Catastrophic Coverage (brand drug) **** |
$100 |
$0 |
$20 |
$0 |
$80 |
n/a |
Catastrophic Coverage (generic drug) **** |
$100 |
$0 |
$20 |
$0 |
$80 |
n/a |
* 25% coinsurance or cost-sharing
** 75% Brand-name Donut Hole Discount
*** 75% Generic Donut Hole Discount
**** In
2024,
the Catastrophic Coverage phase still existed, but plan members did
not have any out-of-pocket costs for formulary drugs after reaching the
plan's $8,000 total out-of-pocket threshold (
TrOOP).
2024 Medicare Part D coverage
Question: How did the Catastrophic Coverage work prior to 2024?
Prior to 2024, in the Catastrophic Coverage phase, you paid either a flat copay fee (set annually) or 5% of the plan's negotiated retail drug cost (whichever was greater) for your formulary medications, depending on the type of drug -- generics or preferred brand drugs that are multi-source drugs vs. all other drugs.
For example,
in 2023, you paid the higher of either 5% of the drug's retail price or $10.35 for brand name drugs or $4.15 for generic drugs in Catastrophic Coverage.
So in 2023, if you purchased a brand-name drug with a retail price of $100 in the Catastrophic Coverage phase, you paid $10.35 for the prescription fill since the fixed $10.35 brand-name drug copay is higher than 5% of the $100 retail drug price (or $5). But, if you purchased a brand-name formulary drug with a retail cost of $300, you paid $15 in the 2023 Catastrophic Coverage phase since 5% of $300 ($15) is more than the 2023 fixed copay of $10.35.
2023 Medicare Part D coverage
More Part D History: Simple example of 2023 Medicare Part D plan coverage costs
Here is how example formulary drug purchases are calculated throughout your 2023 Medicare Part D plan (using the CMS defined standard benefit Medicare Part D plan as a guide).
When you purchase a formulary medication during your 2023 Medicare Part D prescription drug coverage - assuming a $100 retail drug cost (or $300 retail drug cost in our brand-name drug Catastrophic Coverage example) |
|
Retail Cost |
You Pay |
Your Medicare
drug plan pays |
Pharma
Mfgr. pays |
Federal
Govern.
pays |
Amount counting
toward your TrOOP
Threshold
|
Initial Deductible |
$100 |
$100 |
$0 |
$0 |
$0 |
$100 |
Initial Coverage phase * |
$100 |
$25 |
$75 |
$0 |
$0 |
$25 |
Coverage Gap - brand-name ** |
$100 |
$25 |
$5 |
$70 |
$0 |
$95 |
Coverage Gap - generic *** |
$100 |
$25 |
$75 |
$0 |
$0 |
$25 |
Catastrophic Coverage (brand drug) **** |
$300 |
$15 |
$45 |
$0 |
$240 |
n/a |
Catastrophic Coverage (generic drug) **** |
$100 |
$5 |
$15 |
$0 |
$80 |
n/a |
* 25% coinsurance or cost-sharing
** 75% Brand-name Donut Hole Discount
*** 75% Generic Donut Hole Discount
****
In 2023, you paid 5% of retail or $10.35 for brand drugs whatever is higher or
5% of retail or $4.15 for generic or multi-source drugs whatever is
higher (80% paid by Medicare, 15% paid by Medicare plan, and around 5% by plan member)
See:
https://www.democrats.senate.gov/imo/media/doc/inflation_reduction_act_of_2022.pdf
https://www.congress.gov/bill/117th-congress/house-bill/5376/text
https://www.cms.gov/files/document/2026-advance-notice.pdf
https://www.cms.gov/files/document/2025-announcement-pdf.pdf
https://www.cms.gov/oact/tr/2025