In response to questions on previous memoranda, CMS has issued additional guidance on “Closing the Coverage Gap in 2011.” The new guidance addresses: enhanced alternative benefits designs without an initial coverage limit; non-calendar year employer group waiver plans; covered Part D drugs that are not applicable drugs under the Medicare coverage gap discount program; Part D vaccine administration fees; discounts on direct member reimbursements for prescriptions filled at out-of-network pharmacies; Part D compounds; and brand-only deductibles.