NCPA Update: CMS Will Consider Changes to Pharmacy DIR in Part D

Dec 01, 2017

In a 713-page proposed regulation, the Centers for Medicare & Medicaid Services announced it will consider a proposal to account for all pharmacy DIR at point of sale, as NCPA has long urged. CMS argues that the change would increase drug pricing transparency and lower costs for beneficiaries. The proposed rule also attempts to address controversial PBM practices that hinder community pharmacy participation in Part D, citing NCPA input in the proposal. The rule proposes a number of positive changes on an array of topics, including:

  • Defining a "mail order pharmacy" as one that delivers covered Part D drugs via common carrier at mail order cost-sharing rates (a definition that would exclude most independent pharmacies);
  • Restating CMS opposition to Part D plans hindering access to certain specialty drugs via limited pharmacy networks
  • Requiring that Part D plan sponsors have standard terms and conditions for pharmacy network participation available no later than September 15 each year.
  • Prohibiting Part D sponsors from excluding certain pharmacies from their retail network just because the pharmacies may offer other services such as mail delivery or compounding.

Though the rule is only a proposal at this point, it's clear that CMS is paying attention to and agrees with NCPA's input on several important issues. Read NCPA's statement on the impact of the proposed rule on community pharmacy here. NCPA will submit comments to CMS before the Jan. 16 deadline and aggressively support key provisions.