Changes to Plan-to-Plan P2P Month-End Reports

CMS will publish a HPMS memorandum on January 9, 2026, titled “Changes to Plan-to-Plan (P2P) Month-End Reports.” This memo will inform plans of a logic update to the P2P Month-End Reports (Reports 40, 41, 42, and 43) to incorporate the new Medicare Part D Selected Drug Subsidy, introduced under the Inflation Reduction Act (IRA).

Key Changes Effective Calendar Year 2026:

• The P2P Amount in these reports will now equal the sum of:
  • Low Income Cost Sharing Subsidy Amount (LICS)
  • Covered D Plan Paid Amount (CPP)
  • Selected Drug Subsidy
• The Selected Drug Subsidy, like LICS and CPP, must be included in the total P2P amount to ensure the plan submitting the PDE is correctly reimbursed by the plan of record for the covered drug.
• A new Selected Drug Subsidy field will be added to Reports 41, 42, and 43.

These changes will apply starting with the January 2026 Month-End Reports, which will be distributed to plans in mid-February 2026. The updated report layouts are available on the Customer Service and Support Center (CSSC) Operations website. Navigate to “Prescription Drug Program” > “File and Report Layouts” to download the layouts. They will also be included as attachments to the memorandum.

In the event you have questions, please contact CSSC Operations at 1-877-534-2772 (option 2) or by email at csscoperations@palmettogba.com.