NCPA submits comments to CMS’ proposed rule on its CY2025 proposed rule for Medicare Advantage and Medicare Part D

NCPA submitted comments to CMS’ Contract Year 2025 proposed rule for Medicare Advantage and Medicare Part D. In the comments, NCPA strongly supported the increased application of medication therapy management as soon as possible. NCPA opposed further broadening coverage of MTM services without increasing payment to pharmacies, as doing otherwise will create an “unfunded mandate” on pharmacy. Furthermore, NCPA advocated that MTM payments should be commensurate with the care and expertise provided to the patient, not based on generating additional revenue for the plans and the PBMs. NCPA also argued that pharmacies should have flexibility to choose the documentation system(s) they prefer instead of the one(s) required by Part D plans and PBMs.