Pharmaessentia USA Corporation v. United States Department of Health and Human Services

District Court, District of Columbia·Decided September 29, 2025·No. Civil Action No. 2024-3346·Published

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

PHARMAESSENTIA USA CORP., Plaintiff,

v. Case No. 1:24-cv-03346 (TNM)

DEPARTMENT OF HEALTH AND HUMAN SERVICES, et al.,

Defendants.

MEMORANDUM OPINION

PharmaEssentia USA, a drug manufacturer, challenges the Centers for Medicare and Medicaid Services’ (CMS) conclusion that it did not qualify as a “Specified Small Manufacturer.” That decision denied PharmaEssentia the ability to gradually phase in drug discounts the Inflation Reduction Act (IRA) mandates.

The governing statutory scheme is complex, but the dispute is not. The parties agree that PharmaEssentia satisfied all but one of the statutory requirements for a “Specified Small Manufacturer.” Further, whether PharmaEssentia satisfied that requirement turned on whether there were any “costs” incurred because of qualifying dispenses of its drug in 2021. According to CMS’s records, no such “costs” existed. CMS accordingly denied PharmaEssentia’s eligibility request. PharmaEssentia, however, maintains that it made three qualifying drug sales in 2021 and repeatedly offered evidence of those sales to the agency. CMS denied those reconsideration requests, pointing to the lack of evidence in its own records.

This Court’s review of the dispute is narrow. Under the APA, it considers only whether CMS properly applied the governing law and whether it acted arbitrarily and capriciously in

deciding that PharmaEssentia was not eligible for its desired phase-in status. Taking these questions in turn, the Court first rejects CMS’s reading of the governing statutes. The Court then holds that CMS acted arbitrarily and capriciously in making its determination. CMS failed to acknowledge PharmaEssentia’s evidence that it had qualifying drug dispenses. The Court will vacate and remand the decision to CMS.

I.

The Court begins with a brief explanation of the relevant Medicare framework. Then, the Court recounts how this framework affected PharmaEssentia.

A.

Medicare is a federally funded and administered health insurance program for eligible elderly and disabled individuals. See 42 U.S.C. §§ 1395 et seq. “It is administered by CMS, a component of the U.S. Department of Health and Human Services.” Servier Pharms. LLC v. Becerra, No. CV 24-2664, 2025 WL 27352, at *1 (D.D.C. Jan. 3, 2025).

This case concerns Medicare “Part D,” which governs outpatient prescription drug coverage. “Under Part D, qualified Medicare beneficiaries may enroll in a variety of Part D plans, administered by private insurance companies, that contract with CMS to provide coverage for drugs that have been identified by the Medicare statute as ‘covered part D drugs.’” Servier Pharms., 2025 WL 27352, at *1 (cleaned up); see Medicare Prescription Drug, Improvement, and Modernization Act, Pub. L. No. 108-173, § 101(a), 117 Stat. 2066, 2071–2072 (2006) (codified as amended in scattered sections of Title 42 of the U.S. Code). When Congress introduced Medicare Part D in 2003, it allocated drug costs between beneficiaries, insurance companies, and drug manufacturers. 1

1 Part D benefits can be provided by various entities; the Court refers to them collectively as “Part D plans” or “Part D sponsors.” See 42 C.F.R. § 423.4 (defining a “Part D plan sponsor”).

From the start, Medicare Part D had four “layers” of coverage. 42 U.S.C. § 1395w-

102(b) (2006). At first, the beneficiary was responsible for all prescription costs. Id. § 1395w- 102(b)(2) (2006). Once the beneficiary met a deductible, the “coverage” layer kicked in and the insurance company began contributing. Id. § 1395w-102(b)(2), (b)(3) (2006). But when the beneficiary’s annual drug costs reached the “initial coverage limit,” the beneficiary encountered the “donut hole.” Id. § 1395w-102(b)(2), (b)(3) (2006). At that point, a beneficiary had to pay a significant percentage of drug costs until he reached the “annual out-of-pocket threshold” and triggered the “catastrophic coverage” phase. Id. § 1395w-102(b)(4) (2006). Under that final layer, the government covered 80% of the cost of the drug, leaving the remaining amount shared between the Part D plan and the beneficiary. Id. § 1395w-115(b)(1) (2006).

Congress operationalized the government’s subsidization obligations by requiring the Secretary of Health and Human Services to pay a “reinsurance payment amount” to Part D plans. See 42 U.S.C. § 1395w-115(a)(2) (2006). That amount represented “80 percent of the allowable reinsurance costs . . . attributable to that portion of gross covered prescription drug costs . . . incurred in the coverage year after [a Part D beneficiary] has incurred costs that exceed the annual out-of-pocket threshold.” Id. § 1395w-115(b)(1) (2006). The statute defines “gross covered prescription drug costs” as most “costs incurred under the plan.” Id. § 1395w-115(b)(3) (2006). The statute defines “allowable reinsurance costs” as “the part of such costs that are actually paid . . . by the sponsor or organization or by (or on behalf of)” a beneficiary. Id. § 1395(b)(2) (2006). At a high level, Congress ordered the Secretary to pay Part D plans an annual percentage of the total costs the plan incurred on behalf of a particular beneficiary.

Congress gave the Secretary discretion to determine how to pay the Part D plans. 42 U.S.C. § 1395w-115(d)(1) (2006) (“Payments under this section shall be based on such a method

as the Secretary determines.”). And Congress “conditioned” Part D plans’ payment on their “furnishing to the Secretary, in a form and manner specified by the Secretary, of such information as may be required to carry out this section.” Id. § 1395w-115(d)(2)(A) (2006). The Secretary delegated his responsibilities to CMS. See Defs.’ Cross Mot. for Summ. J. (“Defs.’ Mot.”) at 7–8, ECF No. 23-1. CMS used that statutory discretion to promulgate rules specifying the information that Plan D plans must provide to receive payment.

Most importantly, CMS established a system “for cataloguing prescription drug event (PDE) records” to help ascertain the amount due to Part D plans. See generally 70 Fed. Reg. 58,436 (Oct. 6, 2005). “‘Every time a beneficiary fills a prescription covered under Part D,’ CMS explained, ‘plans must submit a summary record called the prescription drug event (PDE) record to CMS.’” Defs.’ Mot. at 9 (quoting 70 Fed. Reg. at 58,437). PDEs do not show “the actual claim paid at the pharmacy.” Id. at 10 (quoting Pl.’s Ex. 2 at 12, ECF No. 22-3). 2 Instead, each data point is a record of the claim created by the Part D plan. Id. (quoting Pl.’s Ex. 2 at 12). “The PDE record contains prescription drug cost and payment data” that allow CMS to determine the amount due to Part D plans. Id. (quoting 70 Fed. Reg. at 58,437). Medicare and its coverage layers have evolved over the past two decades, and CMS has looked to the PDE system as a mechanism for implementing these reforms. See Defs.’ Mot. at 10–11.

This case concerns the Inflation Reduction Act’s (IRA) reforms to Part D in 2022. Pub.

L. No. 117-169, 136 Stat. 1818 (2022). One such reform was the elimination of the “donut hole” coverage gap. See Pl.’s Mot. for Summ. J. (“Pl.’s Mot.”) at 8, ECF No. 22; Defs.’ Mot. at 12; Administrative Record (“A.R.”) 19, ECF No. 28. The IRA closes that gap by requiring drug

2 The Court takes judicial notice of this publicly available document produced by CMS for background purposes. See Fed. R. Evid. 201(b)(2), (d); Pharm. Rsch. & Mfrs. of Am. v. Dep’t of Health & Hum. Servs., 43 F. Supp. 3d 28, 33–34 (D.D.C. 2014).

manufacturers to pay costs previously borne by beneficiaries and Plan D plans. See 42 U.S.C. § 1395w-114c(g)(4)(A). Not all manufacturers had to immediately assume these costs. Two categories of manufacturers can phase in their discount obligations. Id. § 1395w-114c(g)(4).

The first category of phase-in eligibility is for “Specified Manufacturers.” 42 U.S.C.

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