Inflation Reduction Act & Medicare Part D
ADAP Advocacy’s drug pricing policy priorities focus on saving people living with HIV/AIDS money, not cost controls for public or private payors, or policies that benefit healthcare providers rather than patients. The Inflation Reduction Act (IRA), though well-intended, will not save patients money at the pharmacy counter, but it is creating an entirely new set of challenges.
Quick links
Take Action • Blogs • Inforgraphics • Op Eds • Policy Papers • Public Comments • Resources
The IRA enables Medicare to negotiate drug prices as part of a policy-focused effort to lower costs for consumers and reduce federal spending on high-cost medications. It established the Medicare Drug Price Negotiation Program (MDPNP), authorizing the Secretary of the U.S. Department of Health and Human Services to negotiate prices for specific single-source drugs covered under Medicare Part B and Part D. These negotiated prices are capped at a Maximum Fair Price, which is calculated based on factors such as the drug's market price and therapeutic value. The law has numerous unintended consequences that will undoubtedly negatively impact patient care.
ADAP Advocacy is concerned that Sections 11001 and 11002—the sections that establish MDPNP—will create artificial access to care for people living with HIV/AIDS, limit antiretroviral (ARV) medication availability, restrict access to medications to treat other conditions associated with aging with HIV, and stifle future innovation for new therapies. Aside from restricting access to medications, there are other concerns. One of the primary arguments is that the setting of MFPs for ARV medications may inadvertently negatively impact AIDS Drug Assistance Program (ADAP) revenues generated by the 340B Drug Pricing Program.
Blogs
Trump Administration Pushes Two New Rebate Models, But Will They Help Patients?
(January 15, 2026)
The Centers for Medicare and Medicaid Services (CMS) has released information about a new proposed mandatory pricing model—the Guarding U.S. Medicare Against Rising Drug Costs (GUARD) Model—that would assess the inflation rebate amounts paid for certain medications covered under Medicare Part D using a benchmark derived from international pricing information rather than using current domestic benchmarks.
View our blogs archive.
BACK TO TOPWhy are Price Cap Proposals on Medicines Dangerous to Pharmacies and Patients?
(October 30, 2025)
Price cap proposals, like upper payment limits currently being debated by prescription drug affordability boards (PDABs) and Medicare maximum fair prices (MFPs), often assume a simple drug/price supply chain, which doesn’t reflect reality in the United States.
Public Comments
Public Submission Form for Information about Selected Drugs and Their Therapeutic Alternatives: BIKTARVEY
(February 27, 2026)
CMS has grouped Questions 28 through 54 into five topic categories addressed by the set of questions. Specifically, these categories by question number are:
Questions 28-33: Patient- or Caregiver-Focused Input
Questions 34-39: Manufacturer-Focused Input
Questions 40-45: Clinical-Focused Input
Questions 46-51: Health Research-Focused Input
Questions 52-54: Other Public Input
View our public comments archive.
BACK TO TOPGuarding U.S. Medicare Against Rising Drug Costs (GUARD) Model [CMS-5546-P]
(February 20, 2026)
The ADAP Advocacy Association appreciates the opportunity to submit comments on the proposed Guarding U.S. Medicare Against Rising Drug Costs (“GUARD”) Model (file code CMS-5546-P). We commend the Administration and the Centers for Medicare & Medicaid Services (“CMS”) for exploring innovative approaches to address prescription drug costs in Medicare Part D.
RESOURCEs
Reports
The National Community Pharmacy Association (NCPA) report, Unpacking the Financial Impacts of Medicare Drug Price Negotiation, concludes that the IRA’s Medicare Drug Price Negotiation Program puts small and independent pharmacies at substantial financial risk, which could threaten seniors’ access to vital medications and services.