Edge 2026
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Compare Medicare Part D Prescription Drug Plans: Donut Hole Elimination & Inflation Reduction Act Caps

A formulary and benefit phase analysis of Medicare Part D plans under Inflation Reduction Act reforms, eliminating the coverage gap and establishing a $2,000 out-of-pocket cap.

Author: Evelyn Reed, CPC, Pharmacy Benefit Specialist
Published: 2026-10-26
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Empirical Analysis & Findings

## Structural Overhaul of Medicare Part D Prescription Benefits

The Inflation Reduction Act (IRA) enacted the most comprehensive redesign of Medicare Part D since the program's 2006 inception, permanently eliminating the historical coverage gap ('donut hole') and establishing a universal statutory $2,000 annual out-of-pocket spending cap.

### 1. The Redesigned Four-Phase Benefit Architecture

| Benefit Phase | Historical Design (Pre-2025) | Modern IRA Standard Benefit Design | Enrollee Cost Share |
|:--------------|:-----------------------------|:-----------------------------------|:-------------------:|
| Deductible Phase | 100% of drug costs up to $545 | 100% of drug costs up to $590 | 100% |
| Initial Coverage Phase | 25% coinsurance up to $5,030 | 25% coinsurance up to $2,000 TrOOP cap | 25% copay / coinsurance |
| Coverage Gap (Donut Hole)| 25% coinsurance up to $8,000 | ELIMINATED (Phase removed) | 0% (Phase eliminated)|
| Catastrophic Phase | 5% coinsurance (Post-cap) | 0% enrollee liability (Insurer/CMS share)| $0 Out-of-Pocket |

### 2. The Medicare Prescription Payment Plan (M3P)

Beginning in 2025-2026, all Part D enrollees have the statutory right to opt into the Medicare Prescription Payment Plan (M3P). M3P allows beneficiaries to smooth high-cost brand-name and specialty tier prescription out-of-pocket costs into capped, interest-free monthly installments spread across the remainder of the calendar year.

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Medicare Part D CMS Donut Hole Inflation Reduction Act Formulary Tiers M3P

Frequently Asked Questions

What is the maximum out-of-pocket limit for Medicare Part D?

Under the Inflation Reduction Act reforms, Medicare Part D enrollees have a hard statutory out-of-pocket cap of $2,000 per year on covered prescription drugs, after which enrollees pay $0 for the remainder of the calendar year.

What happened to the Medicare donut hole?

The Medicare Part D coverage gap, commonly known as the donut hole, was completely eliminated by statutory restructuring, transitioning directly from initial coverage to catastrophic 100% carrier coverage once the out-of-pocket cap is reached.

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