Don’t skip the fine print on Medicare Part D 2025 contracts

NCPA April 11, 2024

Following up on recent notices to members from NCPA, some PBMs may be offering new contracts for Medicare Part D 2025 plan year networks to individual pharmacies that are OPT-OUT contracts. They would impact the entire 2025 plan year and may require a pharmacy to notify the PBM in writing (via fax) in a short timeframe (as early as the end of April 2024) if you do not want to be enrolled. However, if the pharmacy is part of a PSAO network and the PSAO chooses to enroll in the network, that PSAO agreement supersedes any agreement between the individual pharmacy and the PBM. You should review contract terms to determine if they may be below product acquisition cost and include vague payment terms such as Maximum AWP Discounts and Minimum Dispensing Fees, which will vary depending on plan sponsor. Lastly, pay close attention to any offering to agree that the terms and conditions of participation are reasonable and relevant. NCPA urges member pharmacies to carefully evaluate the financial and other terms of any proposed contract and to adhere to PBM deadlines and any specific notice requirements in their contract with any PBM.