CMS is seeking comments regarding whether the agency should revise a requirement that pharmaceutical manufacturers make payments to Medicare Part D drug plans under the Medicare Coverage Gap Discount Program Agreement via electronic fund transfer (EFT).   Some manufacturers have raised concerns that EFT is not practical when an invoice amount is very low because of bank minimum EFT thresholds and transaction fees. CMS is requesting input on whether it should allow an exception to the EFT requirement, and if so, what the exception should be (e.g., payment by check instead). Comments are due October 7, 2011.