Pharmacy DIR Proposal Supported by Nearly 3,500 Pharmacists, 150+ Pharmacy Stakeholder Organizations

NCPA January 28, 2019

ALEXANDRIA, Va. (Jan. 29, 2019) — A years-long effort led by the National Community Pharmacists Association to build support for a proposal to move pharmacy price concessions to point-of-sale reached a critical milestone on Jan. 25, 2019. Nearly 3,500 pharmacists and 170 patients formally voiced their support for parts of a proposed Centers for Medicare and Medicaid Services drug pricing rule that would eliminate the retroactive nature of pharmacy direct and indirect remuneration fees, or pharmacy DIR.

The proposed changes also received support from more than 150 pharmacy stakeholder organizations representing diverse interests, which unified their voices and submitted a joint letter of support to CMS. Additionally, more than two dozen patient advocacy organizations supported the proposed rule on the premise that, if finalized, the pharmacy DIR fixes will save the average patient nearly $200 per year or more in some cases on their out-of-pocket prescription drug costs.

NCPA submitted its own comments in response to the proposed rule, which is titled "Modernizing Part D and Medicare Advantage to Lower Drug Prices and Reduce Out-of-Pocket Expenses." NCPA joined forces with the National Association of Chain Drugstores and the National Association of Specialty Pharmacy on a joint comment letter asking for a pharmacy DIR fee fix and standardized pharmacy metrics, and also also sent a joint comment letter with the American Society of Consultant Pharmacists and the Senior Care Pharmacy Coalition focusing on harm to seniors with proposed protected class changes, as well as on the need for a new definition of negotiated price and standardized pharmacy measures.

Several letters supporting the proposed DIR fixes are also being sent by members of Congress. Review letters of support for the pharmacy DIR provisions in the proposed drug pricing rule.

"NCPA had asked CMS to include all pharmacy price concessions at the point of sale – or, ideally, eliminate pharmacy DIR altogether – in response to the administration's request for information about its ‘Blueprint to Lower Drug Prices and Reduce Out-of-Pocket Costs,'" said NCPA CEO B. Douglas Hoey, Pharmacist, MBA. "This proposed rule is evidence that we are being heard, and we applaud the administration for putting out this proposal to include pharmacy price concessions at the point of sale. Eliminating the retroactive application of these fees would provide much-needed predictability and stabilization to pharmacy operations, and would save Part D beneficiaries billions of dollars.

"Less uncertainty for pharmacies, lower costs for seniors – that's a no-brainer in our book. And as witnessed in comments to CMS, an overwhelming number agree.

"Now is the time to bring more transparency into our health care system and a reprieve to small business community pharmacies and seniors. We are grateful to the administration for recognizing this, and strongly encourage them to finalize this proposal. Community pharmacists are ready partners in this and other ongoing efforts to lower drugs costs and eliminate pharmacy DIR once and for all."

NCPA's July 2018 response to the administration's RFI to lower drug costs.


Founded in 1898, the National Community Pharmacists Association is the voice for the community pharmacist, representing 22,000 pharmacies that employ 250,000 individuals nationwide. Community pharmacies are rooted in the communities where they are located and are among America's most accessible health care providers. To learn more, visit