NCPA Regulatory Advocacy

NCPA Regulatory Advocacy

NCPA follows regulatory affairs closely and provides comments whenever possible on behalf of its members. Please see below for our most recent comments and letters. For our compounding advocacy, click here. For our advocacy on the Medicare Drug Price Negotiation program and the Inflation Reduction Act generally, click here.

Centers for Medicare and Medicaid Services (CMS) and Health and Human Services (HHS)

  • NCPA comments to CMS on prior authorization proposed rule (June 2026)
  • Joint NCPA/APhA/NACDS/ASCP/NASP/FMI memo to CMS calling on the agency to further regulate standards governing “reasonable and relevant” pharmacy contract terms and conditions under Medicare Part D’s any willing pharmacy requirements (June 2026)[
  • Joint NCPA/APhA/NACDS/ASCP/NASP/FMI/NGA letter requesting a meeting for HHS to formulate the specific “reasonable and relevant” contract terms that prescription drug plan sponsors will be required to offer pharmacies under Medicare Part D (February 2026)
  • NCPA comments to CMS on Advance Notice of Methodological Changes for CY 2027 for Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies (February 2026)
  • Joint NCPA/ASCP comments to CMS/DoL/DoT on transparency in coverage proposed rule (February 2026)
  • Joint NCPA/ASCP comments to CMS on repeal of minimum staffing standards for long-term care facilities interim final rule (February 2026)
  • NCPA comments to CMS on Medicare Part D/Medicare Advantage proposed rule (January 2026)
  • NCPA comments to CMS' calendar year 2026 physician fee schedule (September 2025)
  • NCPA comments to CMS on home health/DMEPOS proposed rule (August 2025)
  • NCPA comments to CMS on end-stage renal disease proposed rule (August 2025)
  • NCPA comments to HHS RFI to de-regulate HHS/Make America Healthy Again (July 2025)

Drug Enforcement Administration (DEA)

  • Joint NCPA/APhA/AACP/AAPP/ACCP/ASCP/ASHP/NASPA/NACDS and others letter calling on DEA to update registration, authorization information to reflect state law (September 2025)

Food and Drug Administration (FDA)

  • NCPA comments to FDA on patient medication information (PMI) (March 2026)
  • NCPA comments to FDA's RFI on access to non-prescription drugs (February 2026)
  • NCPA comments to FDA's small dispensers assessment under the Drug Supply Chain Security Act (DSCSA) (December 2025)

Health Resources and Services Administration (HRSA)

  • NCPA comments on 340B Rebate Model Pilot Program (September 2025)

Department of Labor

  • NCPA comments to Department of Labor re: PBM fee disclosures under ERISA (April 2026)
  • NCPA comments to Department of Labor re: PBM compensation practices under ERISA (August 2025)

TRICARE

  • NCPA comments to TRICARE on Pharmacy Program RFI (May 2026)

Regulatory Advocacy to Congress

  • NCPA letter to Senate regarding pharmacists' role in providing chronic care (November 2025)
  • Joint NCPA/ASCP/SCPC letter to Congress and the Administration endorsing the Preserving Patient Access to Long-Term Care Pharmacies Act (H.R. 5031) (October 2025)