Georgia Medicare Manufacturer Discount Program Guide 2026

The Medicare Manufacturer Discount Program is one of the four pillars of the Inflation Reduction Act's transformative Part D redesign, along with the $2,000 out-of-pocket cap, the Medicare Prescription Payment Plan (M3P), and the expanded Low-Income Subsidy. The Manufacturer Discount Program requires pharmaceutical manufacturers to provide a 10% discount in the initial coverage phase and a 20% discount in the catastrophic phase on applicable brand-name drugs covered under Medicare Part D. Manufacturer participation is effectively mandatory because non-participating manufacturers' drugs are excluded from Part D coverage entirely. The program took effect January 1, 2025, simultaneously with the $2,000 Part D out-of-pocket cap, replacing the pre-IRA Coverage Gap Discount Program (CGDP) that had operated from 2011 through 2024.

The Manufacturer Discount Program was established by Section 11202 of the Inflation Reduction Act of 2022 and codified at Section 1860D-14C of the Social Security Act. Section 11202 simultaneously eliminated the predecessor CGDP at Section 1860D-14A of the Social Security Act. CMS implements the program through the Final Part D Redesign Program Instructions (issued April 2024 for initial 2025 implementation and revised April 2025 for 2026 refinements), the CMS Manufacturer Discount Program Guidance (multiple memoranda), and Manufacturer Discount Agreements that participating manufacturers sign with CMS.

For Georgia eldercare specifically, the Manufacturer Discount Program matters because:

• All Georgia Medicare Part D beneficiaries benefit from manufacturer discounts on brand drugs
• Initial-coverage-phase discounts count toward beneficiary TrOOP, accelerating the path to the $2,000/$2,100 OOP cap
• Catastrophic-phase discounts reduce plan and federal reinsurance burden, supporting program sustainability and indirectly benefiting all beneficiaries through lower premiums
• Specialty drug users see the largest dollar impact, including oncology patients, MS patients, autoimmune patients, and other high-cost specialty drug users
• Coordination with the Drug Price Negotiation Program MFPs (first cycle effective January 1, 2026) compounds savings for the 10 first-cycle drugs

This guide explains the Manufacturer Discount Program in comprehensive detail: the statutory framework, the discount structure, the applicable drug universe, the manufacturer participation mechanism, the TrOOP coordination, the pharmacy adjudication mechanics, the phase-in from CGDP, and the operational details Georgia seniors and their families need to understand how the program reshapes Part D affordability.

• The Medicare Manufacturer Discount Program imposes a 10% discount on brand drugs in the initial coverage phase and a 20% discount in the catastrophic phase on applicable Medicare Part D drugs, effective January 1, 2025
• The 10% initial coverage phase discount counts toward beneficiary TrOOP, accelerating attainment of the $2,000/$2,100 OOP cap
• Applicable drugs include all brand-name drugs, biological products, and authorized generics; standalone generics are excluded
• Manufacturer participation is effectively mandatory: non-participating manufacturers' drugs are excluded from Part D coverage entirely
• The program coordinates with the Drug Price Negotiation Program: Maximum Fair Prices (MFPs) apply as the base price for the 10 first-cycle drugs effective January 1, 2026

By Brevy Care Team

Statutory and regulatory framework

Section 11202 of the Inflation Reduction Act of 2022

Section 11202 of the Inflation Reduction Act of 2022 is the primary statutory authority for the Manufacturer Discount Program. Section 11202 has multiple components:

1. Established the Manufacturer Discount Program at new Section 1860D-14C of the Social Security Act
2. Terminated the Coverage Gap Discount Program at Section 1860D-14A of the Social Security Act, effective with the end of plan year 2024
3. Created transition rules for drugs and manufacturers transitioning from CGDP to the Manufacturer Discount Program
4. Coordinated the Manufacturer Discount Program with the Part D out-of-pocket cap at Section 11201 of the IRA
5. Established the Medicare Prescription Payment Plan (M3P) in coordination

The same Section 11202 also established M3P, so the statutory section is jointly responsible for two of the four IRA Part D redesign pillars.

Section 1860D-14C of the Social Security Act

The Manufacturer Discount Program is codified at Section 1860D-14C (new section added by IRA Section 11202). Key provisions:

• Section 1860D-14C(b): discount structure (10% initial coverage, 20% catastrophic)
• Section 1860D-14C(c): applicable drug definition
• Section 1860D-14C(d): manufacturer participation requirements and agreement
• Section 1860D-14C(e): exclusions for selected drugs (e.g., Drug Price Negotiation drugs)
• Section 1860D-14C(f): coordination with TrOOP
• Section 1860D-14C(g): reconciliation and payment mechanics

Section 1860D-14A SSA (replaced)

The Manufacturer Discount Program replaced the Coverage Gap Discount Program (CGDP) at Section 1860D-14A of the Social Security Act. The CGDP was created by the Affordable Care Act of 2010 and operated from 2011 through 2024, requiring manufacturers to provide a discount on brand drugs in the coverage gap phase of the Part D benefit. The IRA's elimination of the coverage gap (effectively merging it into the initial coverage phase) made the CGDP structurally obsolete. Section 11202 of the IRA terminated the CGDP and replaced it with the new Manufacturer Discount Program structured around the new two-phase post-IRA Part D benefit (initial coverage + catastrophic).

CMS Final Part D Redesign Program Instructions

CMS issued the operational instructions for the Manufacturer Discount Program in two principal documents:

• April 2024 Final Part D Redesign Program Instructions: initial 2025 implementation guidance
• April 2025 Final Part D Redesign Program Instructions (Revised): 2026 refinements

These instructions cover:

• Manufacturer participation and agreement signing
• Per-fill discount calculation methodology
• Pharmacy adjudication mechanics
• Plan-manufacturer reconciliation
• TrOOP crediting
• Drug-level eligibility determinations
• Drug Price Negotiation coordination

CMS Manufacturer Discount Agreement template

CMS publishes the Manufacturer Discount Agreement template that participating manufacturers must sign. The agreement covers:

• Definition of applicable drugs
• Discount calculation methodology
• Reporting requirements
• Audit rights
• Compliance and penalties
• Termination provisions

Discount structure

Initial coverage phase: 10% manufacturer discount

In the initial coverage phase (the phase between the deductible and the $2,000/$2,100 out-of-pocket cap), the manufacturer provides a 10% discount on the negotiated price of applicable brand drugs.

Pre-IRA equivalent: The CGDP (2019-2024) provided a discount on brand drugs in the coverage gap phase. The IRA Manufacturer Discount Program reduced the manufacturer discount percentage but applied it across a much broader range (the entire initial coverage phase, not just the coverage gap).

Calculation example: A brand drug with a negotiated price of $500/fill, manufacturer discount = $50. The beneficiary pays 25% coinsurance on the post-discount price.

Under the post-IRA structure:

• Beneficiary pays 25% coinsurance on the negotiated price
• Manufacturer provides 10% discount that goes to the plan (and counts toward beneficiary TrOOP)
• Plan pays 65% (with the 10% discount offsetting some plan cost)

The exact accounting flows are complex, but the beneficiary's TrOOP includes both their 25% coinsurance and the 10% manufacturer discount, accelerating their path to the OOP cap.

Catastrophic phase: 20% manufacturer discount

In the catastrophic phase (after the beneficiary reaches the $2,000/$2,100 OOP cap), the manufacturer provides a 20% discount on the negotiated price of applicable brand drugs.

The catastrophic-phase discount does not count toward beneficiary TrOOP (the beneficiary has already reached the OOP cap and has $0 cost-sharing for the rest of the year). The 20% discount reduces plan cost and federal reinsurance cost.

Why the two-phase structure

The two-phase discount structure is designed to:

1. Accelerate beneficiary cap attainment: the 10% initial coverage discount counts toward TrOOP, helping beneficiaries reach the $2,000/$2,100 cap sooner
2. Reduce program costs: the 20% catastrophic discount reduces plan and federal reinsurance burden, supporting Part D sustainability after the IRA-eliminated coverage gap
3. Maintain manufacturer financial contribution: although the percentage is lower than CGDP's discount, the broader applicability (entire initial coverage phase + catastrophic phase, not just coverage gap) maintains manufacturer financial contribution to Part D

Applicable drug universe

Included drugs

• Brand-name drugs: all brand drugs with manufacturer participation in the Manufacturer Discount Program
• Biological products: biological products including biosimilars (subject to specific rules)
• Authorized generics: generics marketed by the brand manufacturer (under the same New Drug Application)

Excluded drugs

• Standalone generic drugs: generic drugs without authorized generic status (no manufacturer discount)
• Selected Drug Price Negotiation drugs: drugs subject to the Maximum Fair Price (MFP) under the Drug Price Negotiation Program are coordinated separately (see below)
• Some vaccines: most ACIP-recommended vaccines are excluded from cost-sharing entirely under the IRA, so the discount mechanics do not apply
• Drugs without manufacturer participation: drugs from manufacturers that have not signed the Manufacturer Discount Agreement are excluded from Part D coverage entirely

Brand vs generic distinction

The Manufacturer Discount Program is structured around brand drugs because the policy rationale is:

• Brand drugs are typically high-cost
• Manufacturers have pricing power on brand drugs (patent or biologic exclusivity)
• Generic drugs are typically already low-cost and price-competitive
• Standalone generics do not need additional discount

Authorized generics are included because they are marketed by the brand manufacturer (under the brand's NDA), so the brand manufacturer retains pricing influence.

Biosimilars

Biosimilars (biological products that are highly similar to a reference biologic) are subject to specific rules:

• Biosimilars from the reference biologic manufacturer or its affiliates are subject to the Manufacturer Discount
• Independent biosimilar manufacturers must separately sign the Manufacturer Discount Agreement
• Interchangeable biosimilars (designated by FDA) have similar coverage and discount treatment to brand biologics

Manufacturer participation: effectively mandatory

The "all-or-nothing" rule

Manufacturer participation in the Manufacturer Discount Program is effectively mandatory because Section 1860D-14C(d) of the Social Security Act provides that:

• Non-participating manufacturers' drugs are excluded from Part D coverage entirely
• Non-participating manufacturers face a 100% excise tax on Part D drug sales under the IRC

This dual penalty structure makes non-participation commercially infeasible. As of 2025, virtually all major pharmaceutical manufacturers have signed the Manufacturer Discount Agreement.

Comparison to CGDP

The CGDP also had an effectively mandatory participation structure under the ACA. Section 11202 of the IRA carried over this approach to the Manufacturer Discount Program, ensuring continued universal manufacturer participation.

Manufacturer Discount Agreement signing

Participating manufacturers sign the Manufacturer Discount Agreement with CMS. The agreement specifies:

• The discount calculation methodology
• Reporting requirements (quarterly drug-level data)
• Payment timing (typically quarterly invoicing)
• Audit rights and CMS oversight
• Compliance penalties
• Termination provisions (with significant lead time required)

Manufacturer-side operations

Participating manufacturers must:

• Maintain drug-level data on Part D dispensing
• Calculate per-fill discount amounts
• Reconcile with plans and CMS quarterly
• Pay invoiced discount amounts
• Report to CMS for federal program coordination

Pharmacy adjudication mechanics

Real-time adjudication at point of sale

At the pharmacy point of sale, the Part D plan adjudicates the claim:

1. Pharmacy submits claim to plan with NDC, days supply, quantity
2. Plan determines drug eligibility for Manufacturer Discount Program
3. Plan calculates beneficiary cost-sharing based on benefit phase (deductible, initial coverage, catastrophic) and LIS status
4. Plan applies manufacturer discount (10% or 20%) to determine plan-paid portion
5. Pharmacy receives total payment from plan (beneficiary cost-sharing portion already paid at counter; manufacturer discount and plan payment combined)

The beneficiary does not see the manufacturer discount as a separate line item; the beneficiary simply pays their cost-sharing as calculated.

TrOOP accumulation

The plan tracks TrOOP for each beneficiary:

• Beneficiary deductible payments: count toward TrOOP
• Beneficiary initial coverage phase cost-sharing: count toward TrOOP
• Initial coverage phase manufacturer discount (10% on brand drugs): count toward TrOOP
• Catastrophic phase manufacturer discount (20% on brand drugs): do NOT count toward TrOOP (beneficiary at $0 OOP anyway)
• Premium payments: do NOT count toward TrOOP
• Plan payments: do NOT count toward TrOOP

Once TrOOP reaches the OOP cap ($2,000 in 2025, $2,100 in 2026), the beneficiary enters the catastrophic phase with $0 cost-sharing.

Plan-manufacturer reconciliation

Quarterly:

• Plan tabulates total manufacturer discount amounts due per manufacturer
• Plan invoices manufacturer
• Manufacturer pays plan
• Plan reports to CMS

Federal reinsurance (CMS) also reconciles with plans quarterly.

Coordination with Drug Price Negotiation Program

Selected drugs subject to Maximum Fair Price

The IRA Drug Price Negotiation Program selected 10 drugs in the first cycle effective January 1, 2026 with Maximum Fair Prices:

• Eliquis (apixaban)
• Jardiance (empagliflozin)
• Xarelto (rivaroxaban)
• Januvia (sitagliptin)
• Farxiga (dapagliflozin)
• Entresto (sacubitril/valsartan)
• Enbrel (etanercept)
• Imbruvica (ibrutinib)
• Stelara (ustekinumab)
• Fiasp/NovoLog (insulin aspart)

For these 10 drugs, the Maximum Fair Price replaces the negotiated price between plan and manufacturer:

• Beneficiary cost-sharing is calculated on the MFP (lower than pre-MFP list)
• Manufacturer discount is calculated on the post-MFP price
• Combined effect: significantly lower per-fill cost for both beneficiary and plan

The Manufacturer Discount Program continues to apply to these drugs, but the MFP serves as the base price for cost-sharing and discount calculations.

Second cycle (effective January 1, 2027)

The second cycle selected additional drugs with MFPs effective January 1, 2027. The Manufacturer Discount Program will apply to these drugs in the same coordinated manner.

Third cycle (effective January 1, 2028)

The third cycle will include Part B drugs in addition to Part D drugs. The Manufacturer Discount Program structure remains unchanged.

Coordination with LIS

For Low-Income Subsidy (LIS) beneficiaries:

• LIS beneficiaries pay LIS-tier copays (~$1.55-$4.90 generic, ~$4.60-$12.65 brand)
• Manufacturer discounts still apply to applicable drugs
• The manufacturer discount does NOT increase the LIS beneficiary's cost-sharing (LIS copay is already capped)
• The manufacturer discount reduces plan and federal reinsurance burden on LIS claims
• LIS claims are reconciled through plan-manufacturer-CMS three-way settlement

In effect, manufacturer discounts on LIS claims flow to the plan and federal government, not to the LIS beneficiary (who already has very low cost-sharing).

Coordination with insulin cost-sharing cap

For insulin claims subject to the insulin cost-sharing cap:

• Beneficiary pays the monthly cap or less (LIS may pay lower)
• Manufacturer discounts apply on insulin brand drugs
• The discount reduces plan and federal reinsurance cost
• Beneficiary's capped cost-sharing is unaffected

Phase-in from CGDP

CGDP termination

The CGDP (Section 1860D-14A SSA) operated 2011-2024. Key milestones:

• End of plan year 2024: CGDP terminated
• January 1, 2025: Manufacturer Discount Program begins

Transition rules

CMS published transition rules for drugs and manufacturers moving from CGDP to the Manufacturer Discount Program:

• All CGDP-participating manufacturers automatically transitioned to Manufacturer Discount Program (subject to signing the new Agreement)
• Drug-level participation continued seamlessly
• 2024 plan-year CGDP reconciliations completed through 2025
• 2025+ Manufacturer Discount Program operates independently

Federal reinsurance coordination

Under the post-IRA Part D structure, plan payments, the manufacturer discount, and federal reinsurance together cover catastrophic-phase drug costs. The beneficiary has $0 cost-sharing in the catastrophic phase (post-OOP cap).

Federal reinsurance is funded by general Treasury revenue and pays the federal share of catastrophic-phase drug costs. The 20% manufacturer discount in the catastrophic phase reduces federal reinsurance exposure correspondingly.

Georgia-specific impact

Population

Georgia Medicare beneficiaries enrolled in Part D or MA-PD plans all benefit from manufacturer discounts on brand drugs. LIS beneficiaries receive discounts that flow to the plan and federal government rather than to the beneficiary directly. Non-LIS beneficiaries receive discounts that count toward TrOOP, accelerating cap attainment.

Specialty drug users

Georgia Medicare specialty drug users see the largest dollar impact:

• Oncology patients at Emory Winship Cancer Institute, Piedmont Cancer Institute, Northside Cancer Institute, NGMC oncology: branded oncology agents averaging $10,000-$20,000+ per 30-day supply benefit substantially from discounts
• MS patients at WellStar MS Center, Emory Neurology: branded DMTs benefit from discounts
• Autoimmune patients at Emory Rheumatology, Atrium Navicent Rheumatology: biologics like Stelara, Enbrel, Humira benefit
• CLL/leukemia patients at Emory Winship, NGMC: Imbruvica and similar oral oncology agents benefit

Plan operational considerations

Georgia Part D / MA-PD plan sponsors (Humana, UnitedHealthcare, Aetna, Anthem, Wellcare, Cigna) must:

• Adjudicate manufacturer discount at point of sale
• Track TrOOP including manufacturer discount in initial coverage phase
• Reconcile quarterly with manufacturers
• Report to CMS for federal reinsurance settlement
• Coordinate with Drug Price Negotiation MFPs (first cycle Jan 1, 2026)

Pharmacy operational considerations

Georgia pharmacy networks (Walgreens, CVS, Walmart, Kroger, independent pharmacies, specialty pharmacies at Emory, NGMC, Piedmont, Phoebe Putney, WellStar) must:

• Submit claims with NDC and quantity data
• Receive consolidated payment (beneficiary cost-sharing + plan payment + manufacturer discount)
• Coordinate with plan for retroactive adjustments (e.g., LIS approval, best-available-evidence)

14 best practices for Georgia seniors and families

1. Understand that the manufacturer discount is automatic: beneficiaries do not need to apply for it; pharmacies and plans handle adjudication automatically.

2. Verify your Part D plan's TrOOP accumulation: for non-LIS beneficiaries, the 10% manufacturer discount on brand drugs counts toward TrOOP. Verify by reviewing your Explanation of Benefits or calling your plan.

3. For specialty drugs, expect rapid TrOOP accumulation: high-cost specialty drugs reach the $2,000/$2,100 cap within 1-2 fills due to combined cost-sharing and manufacturer discount.

4. For LIS beneficiaries, the discount does not change your cost: LIS copays are capped at ~$4.60-$12.65 for brand drugs; manufacturer discount flows to plan/federal but does not reduce your already-low LIS copay.

5. Coordinate with the insulin cap: the monthly insulin cap is the ceiling; manufacturer discount mechanics apply but do not increase your payment.

6. Coordinate with the Drug Price Negotiation Program: for the 10 first-cycle MFP drugs (effective January 1, 2026), the MFP serves as the base price; manufacturer discount applies on top.

7. Use Medicare Plan Finder: Medicare.gov/plan-compare reflects the post-IRA discount and cap structure; compare plans annually during AEP (October 15-December 7).

8. Review your Explanation of Benefits monthly: verify TrOOP accumulation and OOP cap progress.

9. Use M3P (Medicare Prescription Payment Plan) if needed: for high-cost early-year fills (e.g., oncology, MS DMT), M3P spreads OOP payments monthly. Available all Part D plans.

10. Consult GeorgiaCares SHIP: 1-866-552-4464 for free annual plan comparison incorporating Manufacturer Discount Program dynamics.

11. For dual-eligibles, the LIS pathway provides the most affordability: Georgia DCH dual-eligibility provides auto-LIS, lower copays than non-LIS.

12. Specialty pharmacy users: verify network status: for high-cost biologics, ensure your specialty pharmacy is in-network with your Part D plan.

13. For oncology and complex specialty drug regimens, request pharmacy navigation: Emory Winship, Piedmont Cancer Institute, NGMC oncology, and other major Georgia cancer centers have pharmacy navigators experienced in IRA Part D mechanics.

14. Plan for January high-cost fills with M3P: January is the cap month for high-spend beneficiaries; M3P smoothing prevents the full OOP cap hitting in a single month.

14 common issues and how to resolve them

1. Pharmacy charged full price (no manufacturer discount applied): Plan likely did not adjudicate discount correctly. Call plan to verify and request retroactive correction.

2. TrOOP not accumulating manufacturer discount: Verify EOB. If discount not credited, contact plan for correction. SHIP can assist.

3. LIS beneficiary charged more than LIS copay: LIS overrides manufacturer discount mechanics for beneficiary cost-sharing. Charge should be at LIS tier.

4. Drug not covered (excluded from Part D): Likely a non-participating manufacturer. Request formulary exception or seek alternative therapy. Most major drugs are covered.

5. MFP drug pricing confusion: For first-cycle MFP drugs (Eliquis, Jardiance, etc.), the MFP applies starting January 1, 2026. Cost-sharing should reflect MFP. Verify with plan.

6. Catastrophic phase $0 OOP but pharmacy charging: Plan adjudication error. Verify TrOOP has reached the cap; if so, beneficiary owes $0.

7. Plan denying brand drug due to manufacturer non-participation: Limited cases. Confirm via plan formulary. May require manufacturer outreach to participate.

8. Manufacturer Patient Assistance Program (PAP) interaction: Manufacturer PAPs may provide additional support; coordinate with PAP and plan. PAP contributions may affect TrOOP (varies).

9. Coupon use prohibited: Medicare Part D beneficiaries cannot use manufacturer copay coupons. Coupons are limited to commercial insurance.

10. Specialty pharmacy delays: Verify network status; switch if necessary.

11. Annual enrollment plan switch confusion: New plan may have different formulary; verify drug coverage and tier before switching.

12. Out-of-pocket cap calculation discrepancy: Plans must include manufacturer discount in TrOOP. If not, request correction.

13. M3P opt-in coordination: M3P does not change total amount; spreads over remaining months. Coordinate with plan if confused.

14. Best-available-evidence for retroactive LIS: If LIS approval is retroactive, plan must adjust prior claims; manufacturer discount mechanics adjust accordingly.

Worked examples

Example 1: Fulton 70 -- Atlanta CLL Imbruvica + MFP + manufacturer discount + cap

Profile: 70-year-old Atlanta retiree, chronic lymphocytic leukemia (CLL), Emory Winship Cancer Institute, prescribed Imbruvica (ibrutinib) at a high monthly specialty drug cost.

2026 scenario (post-MFP):

• MFP applies to Imbruvica 2026, significantly reducing the base price from the pre-IRA list
• January 2026 first fill:
  • Deductible: beneficiary pays the annual deductible
  • Initial coverage phase: 25% coinsurance on the remaining cost, with 10% manufacturer discount counting toward TrOOP
  • In practice, combined cost-sharing and manufacturer discount reach the $2,100 cap on the first fill
• Rest of 2026: $0 cost-sharing
• M3P spreads payments over remaining months

Pre-IRA (2023): Would have paid substantially more OOP for the year. Post-IRA savings: significant due to combined MFP and cap.

Example 2: DeKalb 75 -- Dual-eligible LIS no manufacturer discount impact

Profile: 75-year-old DeKalb full dual-eligible, takes 7 medications including 3 brand drugs.

Manufacturer discount mechanics:

• LIS copays apply: $1.55-$4.60 generic, $4.60-$12.65 brand
• Manufacturer discount applies but reduces plan/federal cost only
• Beneficiary cost-sharing unchanged (already at LIS tier)
• Annual OOP: low due to LIS

Plan benefit from manufacturer discount: plan and federal reinsurance cost is reduced across the 3 brand drugs.

Example 3: Cobb 68 -- MS DMT manufacturer discount + cap

Profile: 68-year-old Cobb resident, relapsing-remitting MS, WellStar MS Center, oral DMT at a high monthly cost.

2026 scenario:

• DMT not on first-cycle MFP list
• January 2026 fill: 25% coinsurance + 10% manufacturer discount + deductible
• TrOOP cap reached on first January fill
• M3P spreads to monthly payments
• Rest of 2026: $0 OOP

Manufacturer discount value: significant dollar amount per fill counted toward TrOOP, accelerating cap attainment.

Example 4: Worth 72 -- Rural multi-medication scenarios

Profile: 72-year-old Worth County rural resident, 8 medications mix of generics + brand inhalers + Nucala biologic for severe asthma.

Manufacturer discount mechanics:

• Generics (5 drugs): no manufacturer discount
• Brand inhalers (2 drugs): 10% discount in initial coverage
• Nucala biologic: 10% discount in initial coverage + 20% in catastrophic if reached
• TrOOP cap reached around May
• $0 OOP June-December
• M3P optional

Annual savings vs pre-IRA: substantial due to combined cap + discount effects.

Example 5: Bibb 80 -- Stelara MFP + manufacturer discount + cap

Profile: 80-year-old Bibb County (Macon) severe psoriatic arthritis, Atrium Navicent Rheumatology, Stelara (ustekinumab) every 8 weeks.

2026 scenario:

• Stelara MFP 2026 reflects a significant reduction from the pre-IRA list price
• January 2026 first dose:
  • Deductible + 25% coinsurance + 10% manufacturer discount counted toward TrOOP
  • First dose alone hits the $2,100 cap
• Rest of 2026: $0 OOP
• M3P spreads monthly payments

Combined IRA savings: substantial vs pre-IRA without MFP and cap.

Example 6: Hall 67 -- Imbruvica MFP + manufacturer discount + cap

Profile: 67-year-old Hall County (Gainesville) CLL, NGMC oncology, Imbruvica daily.

2026 scenario: Same as Fulton 70 (Example 1) -- first January fill hits cap, $0 rest of year, M3P optional.

NGMC oncology coordination: Pharmacy navigator assists with M3P opt-in and IRA mechanics explanation.

1. What is the Medicare Manufacturer Discount Program?

A federal pharmaceutical manufacturer rebate program established by Section 11202 of the Inflation Reduction Act of 2022 (Section 1860D-14C SSA) that imposes a 10% discount on brand drugs in the initial coverage phase and 20% in the catastrophic phase of Medicare Part D. Effective January 1, 2025.

2. Is the discount automatic?

Yes. Beneficiaries do not apply for the discount. Pharmacies and plans handle adjudication automatically.

3. Does the discount count toward my TrOOP / out-of-pocket cap?

The 10% initial coverage phase discount counts toward TrOOP. The 20% catastrophic phase discount does not (beneficiary already has $0 OOP in catastrophic).

4. What is the OOP cap?

$2,000 in 2025, $2,100 in 2026 (CPI-U adjusted), with continuing CPI adjustment in subsequent years.

5. Where can I get more information?

Medicare 1-800-MEDICARE; CMS Part D Redesign Program Instructions at cms.gov; GeorgiaCares SHIP 1-866-552-4464.

Get help

• Medicare: 1-800-MEDICARE (1-800-633-4227), Medicare.gov
• CMS Part D Redesign: cms.gov/inflation-reduction-act-and-medicare/part-d-redesign-program-instructions
• GeorgiaCares SHIP: 1-866-552-4464
• Medicare Rights Center: 1-800-333-4114
• Patient Advocate Foundation: 1-800-532-5274
• NeedyMeds: 1-800-503-6897
• Georgia DCH Member Services: 1-866-211-0950
• Magellan Medicaid Administration GA: 1-800-424-9760
• Atlanta Legal Aid: 404-377-0701
• GA Legal Services: 1-800-498-9469
• Eldercare Locator: 1-800-677-1116
• 211 Georgia: 211.org
• SSA: 1-800-772-1213
• Humana: 1-800-457-4708
• UnitedHealthcare Medicare: 1-800-721-0627
• Aetna Medicare: 1-800-282-5366
• American Cancer Society: 1-800-227-2345
• MS Association of America: 1-800-532-7667

Find personalized help understanding your Medicare Part D options at brevy.com.

This article is part of Brevy's Georgia Medicaid and Medicare resource library. Last verified May 14, 2026. The Medicare Manufacturer Discount Program operational details are subject to CMS guidance updates; verify current policy at cms.gov.