Excerpt: The Centers for Medicare & Medicaid Services (CMS) is concerned that certain new requirements it has established for Medicare Part D plans (i.e., reporting the pass-through prices instead of lock-in prices, and treating amounts retained by the pharmacy benefit manager or other intermediary contracting organization as administrative costs) will, if applied to the retiree drug subsidy program, induce employers to terminate their programs or place their retirees in a Part D plan because of the reduced subsidy. As a result, CMS has postponed applying these changes to the retiree drug subsidy program and is requesting further comments. 74 Federal Register 1494 & 1550 (January 26, 2009).

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