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if ever implemented.
My short reply is "I don't know"
My longer answer is I don't imagine it would be an explicit, formulaic combination - more some kind of actuarial acknowledgment that in '25 the Rx share of plans' spending suddenly jumps up.
Feels like somewhere there's probably some data that suggests what share of beneficiaries currently take a dollar volume of meds that would push them above a $2k cap, which would permit some spitballing on the distribution of the $ we're talking about. I've been too lazy to look but it's probably somewhere associated with the measure that implemented that cap...who knows, the forecast may be much lower than I'm currently imagining....
EDIT: sure enough, the forecast impact is lower than I was imagining. This 8/18/22 Kaiser Family Foundation piece provides some details (about 1/2 way down).
All those people we are seeing on Eliquis or Xarelto? They'll be paying $100 a month premium in 2025.
I am finding more PAP's expanding their qualifying requirements and no longer exclude those with a Medicare PDP. There is an attestation form as part of the application where you agree to not try and use your PDP plus the PAP.
note that they stopped paying commission on it, too)
the detectable uptick in non-commissioned plans, for whatever reasons, probably deserves its own thread ..
I predict, going forward, more and more plans will be non-commissionable