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News & Press: Federal Regulation

NCPA in Part D Rule Comments: End Retroactive Pharmacy DIR Fees

Wednesday, January 17, 2018   (0 Comments)
Posted by: Janet Anderson
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ALEXANDRIA, Va. (Jan. 17, 2018) – In comments submitted in support of the Centers for Medicare & Medicaid Services’ proposed 2019 Medicare Part D rule, the National Community Pharmacists Association has endorsed CMS’ plan to consider assessing pharmacy DIR fees at point of sale.  The association offered input on several other provisions in the rule as well.

“We commend CMS for addressing in this proposed rule troublesome practices in the Part D program and encourage the agency to implement these provisions to produce greater convenience and savings for Medicare beneficiaries and greater transparency and fairness for pharmacies,” said NCPA CEO B. Douglas Hoey, Pharmacist, MBA.

“NCPA and its allies urge CMS to stand firm against pushback from PBMs, who oppose having pharmacy price concessions rolled into the initial adjudication process for prescription drugs, even though doing so is in the interest of patients who need the Part D benefit the most.”

NCPA’s comments included the following points:

  • NCPA fully supports CMS’ recommendation that PBMs be required to account for pharmacy price concessions at the point of sale, rather than retrospectively.
  • NCPA backs the revised definition of mail order pharmacy and retail pharmacy, which allows patients to continue getting their prescription drugs from the same pharmacy.
  • NCPA endorses CMS’ proposal that PBMs may not require onerous pharmacy accreditation and credentialing requirements that go beyond state laws.
  • NCPA supports CMS’ proposal to mandate the timeline for when Part D standard terms and conditions are given to pharmacies.
  • NCPA is concerned that revisions to communications materials and activities could create loopholes where incomplete or misleading information is provided to patients.  

In addition to NCPA’s comments, approximately 1,000 independent community pharmacist owners each submitted their own comments to CMS before the Jan. 16 deadline.


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