NCPA and the National Association of Chain Drug Stores submitted joint comments on CMS’ Medicare $2 Drug List Model, arguing for reasonable reimbursement guardrails for pharmacies.
Under this model, Part D plans would be encouraged to offer a standardized list of approximately 150 generic drugs with a maximum copayment of $2 for a one-month supply.
To ensure protection for pharmacies under this model, NCPA and NACDS called on CMS to provide fair and transparent reimbursement for the generic drugs on the list; require plans and PBMs to include all pharmacies that offer the generic drugs on the list in their networks and prohibit any network restrictions or patient steering to an affiliated pharmacy that would restrict beneficiary choice; require plans and PBMs to ensure reasonable and relevant contract terms and conditions with pharmacies; monitor the effect of the $2 drug model on pharmacy reimbursement and viability, beneficiary access and satisfaction and adjust the model as needed to protect the interests of pharmacies and the beneficiaries they serve; and delay the model’s implementation until 2026 and/or start with a smaller subset of drugs commonly prescribed and dispensed generics to help the drug supply chain prepare and understand the downstream effects of the model on community pharmacies.
