How Part D Initial Coverage Limit (ICL) is Applied in the Part D Plan

SAS Name

This variable indicates whether Part D plan applies the Medicare-defined Part D Initial Coverage Limit (ICL) Amount.


The Initial Coverage Limit (ICL) phase of the Part D benefit is also referred to as the coverage gap.

The CCW constructs the Plan Characteristics File from information submitted by plan sponsors to CMS’s Health Plan Management System (HPMS).

Employer and National Program of All-inclusive Care for the Elderly (PACE) plans are waived from reporting Plan Benefit Package information.

For those plans that did not report, the value of this variable will be blank.

Source: CMS (HPMS Files)

Code Code value
1 Medicare-defined Amount
2 Plan-defined Amount
3 No ICL