2025 is the first year of the redesigned Medicare Part D benefit. The coverage gap is gone, annual out-of-pocket spending on covered Part D drugs is capped at $2,000, and beneficiaries can enroll in the Medicare Prescription Payment Plan to spread their costs across the year in monthly installments. These changes remove real financial barriers for patients. They also change the economics and the workload for health plans and provider organizations, and they make one unglamorous clinical task more important than ever: an accurate, reconciled medication list.
What Changed in Part D
The Inflation Reduction Act restructured Part D into three phases (deductible, initial coverage and catastrophic) and set the out-of-pocket threshold at $2,000 for 2025. Once a beneficiary reaches it, there is no cost sharing for covered drugs for the rest of the year. CMS has announced that the threshold will rise to $2,100 in 2026.
The Medicare Prescription Payment Plan, available since January 1, 2025, lets enrollees pay their out-of-pocket costs in monthly amounts rather than at the pharmacy counter. In its CY 2026 final rule, CMS finalized automatic renewal, so participants will continue in the program for the next year unless they opt out.
Plans also absorb a larger share of catastrophic costs under the redesign, which raises the financial stakes of polypharmacy, duplicate therapy and avoidable adverse events. And CMS expanded Medication Therapy Management eligibility for 2025, lowering the cost threshold to $1,623 and requiring plans to include all core chronic diseases, including HIV/AIDS, in their targeting criteria. More members now qualify for comprehensive medication reviews.
Why Reconciliation Matters More Now
Adherence measures depend on accurate data
The Part D medication adherence measures for diabetes medications, RAS antagonists and statins are among the most heavily weighted measures in the Star Ratings program. Lower cost sharing should help adherence for some members, but it does not solve the operational problems that drive non-adherence: patients who stopped a drug on a specialist's advice, duplicate therapies from multiple prescribers, a 90-day supply at one pharmacy and a 30-day fill at another, or a medication changed during a hospital stay. Without a reconciled list, outreach teams waste calls on patients who are actually adherent, and miss those who are not.
Care management starts with knowing what the patient takes
A care manager cannot build a credible plan around a medication list that is out of date. Pharmacy fill data, the EHR medication list and what the patient reports frequently disagree. Discrepancies are often largest after transitions of care, when new medications start, old ones stop, and doses change. Reconciliation is the step that turns three partial lists into one accurate one.
Safety risk grows with complexity
Older adults with multiple chronic conditions often fill prescriptions from several prescribers and more than one pharmacy. Each additional source increases the chance of interacting drugs, therapeutic duplication or a high-risk medication that no single clinician is tracking. These are not abstract risks. Adverse drug events are a recognized source of preventable emergency visits and admissions in older adults.
Documentation and risk adjustment benefit too
Medications are evidence of treatment. A reconciled list linked to active diagnoses supports documentation of monitoring and treatment for chronic conditions, and it can surface a medication with no documented indication, which is a clinical question for the provider to evaluate. It is not a code, but it is a reason to look.
What Good Reconciliation Looks Like
Reconciliation is more than asking the patient to read their pill bottles. A disciplined process includes:
- Consolidate sources. Bring together pharmacy fill history, the EHR medication list, discharge summaries and the patient's own report.
- Resolve discrepancies. For each medication, determine whether the patient is taking it, at what dose and frequency, and whether it is still intended.
- Check for interactions and duplication. Flag clinically significant drug-drug interactions, duplicate therapy within a class and high-risk medications for older adults.
- Link to indications. Confirm each medication maps to a documented condition and each treated condition has appropriate therapy.
- Address cost and access. Ask about affordability, and where appropriate explain the out-of-pocket cap and the Medicare Prescription Payment Plan, which may help members who face high costs early in the year.
- Document and communicate. Record the reconciled list, the changes made and who was informed, and share it with the care team and the patient.
When to Reconcile
Every encounter is an opportunity, but some moments carry more value than others:
- Within days of a hospital or skilled nursing discharge.
- At the Annual Wellness Visit and other comprehensive visits.
- When a member enters care management or an MTM program.
- When adherence data shows a gap, before outreach assumes non-adherence.
- When a new prescriber or pharmacy appears in claims data.
Operational Questions for Leaders
For VPs of Care Management and Pharmacy, a few questions reveal how mature the current process is. Is pharmacy fill data available to clinicians and care managers at the point of contact, or only in reports? Does adherence outreach confirm the medication list before contacting a member about a gap? Are post-discharge reconciliations completed and documented consistently? Are interaction and duplication checks automated, with pharmacist review for complex cases? Is reconciliation tied to the care plan, so medication issues become tracked goals and interventions?
Bringing It Together
Curitics handles reconciliation as part of the care workflow: pharmacy fills are consolidated with the clinical medication list and checked by AI for interactions, the reconciled list feeds AI-assisted care plan drafting, and HEDIS gap tracking keeps adherence and medication review measures in view. Connected telephony matches calls to the member, so the reconciled list is in front of the care manager during outreach.
The Takeaway
The Part D redesign lowers costs for patients, but it does not, by itself, make medication use safer or more consistent. That still depends on knowing exactly what each patient is taking and why. In 2025, a clean, reconciled medication list is a quality measure strategy, a care management foundation and a safety control at once.
