NCPA and NACDS are urgently requesting CMS examine more carefully recent changes to the National Average Drug Acquisition Cost (NADAC) price benchmark, which have dramatically reduced pharmacy reimbursement in Medicaid and some Medicare plans beginning mid-April. The NADAC changes threaten access to care under Medicaid, especially in underserved areas. Furthermore, these changes are arbitrary and capricious and did not proceed through the necessary rulemaking process, nor did CMS seek public feedback and comments as is historically done. CMS told our organizations that it increased the number of pharmacies surveyed from 2,500 to 4,000 and that shift contributed to the decline in NADAC prices. At the same time, CMS implemented a new methodology for calculating the NADAC rates.
We are requesting that CMS pause the changes and utilization of the new NADAC methodology until stakeholders have been offered an opportunity to review the new methodology, provided the justification for such methodology, and given a chance to comment; or halt utilization of the new methodology and return to the previous methodology used to calculate rates prior to the publication of the April 17, 2024 NADAC rate file.
In addition, CMS should explain when the increase in the number of surveyed pharmacies took effect, provide the reason for the increase, and seek comment from stakeholders regarding such change. We urgently request that CMS and HHS halt the implementation of the new standard until there is better clarity around the specific changes to NADAC rate calculations, CMS’ rationale for implementing modifications to the survey and process, and why stakeholders were not given an opportunity to comment.
