The Medicare Rights Center (Medicare Rights) appreciates this opportunity to comment on the Medicare Prescription Payment Plan (MPPP) draft guidance. Medicare Rights is a national, nonprofit organization that works to ensure access to affordable and equitable health care for older adults and people with disabilities through counseling and advocacy, educational programs, and public policy initiatives. Each year, Medicare Rights provides services and resources to over three million people with Medicare, family caregivers, and professionals.

Based on this experience, we know people with Medicare are uniquely impacted by high and rising drug prices. This is partly due to utilization and health status. Over two-thirds of Medicare beneficiaries have multiple chronic conditions, and Part D enrollees take 4 to 5 prescriptions per month, on average. Many live on fixed or limited incomes that cannot keep pace with rapidly escalating drug prices. Half of all beneficiaries, nearly 30 million people, live on $29,650 or less per year, and one quarter have less than $8,500 in savings.3 Health care costs comprise a large and disproportionate share of beneficiaries’ limited budgets: nearly 30% of Medicare households spend 20% or more of their income on health care, compared to only 6% of non-Medicare households.4 Out-of-pocket costs for prescription drugs represent a significant share of this amount, accounting for nearly one out of every five beneficiary health care dollars.5 Most people with Medicare cannot afford to pay more for care.