On April 4, the Centers for Medicare & Medicaid Services released the final CY2026 Part D rule, which contains several important provisions for NCPA members, some good and some bad. NCPA is not pleased that CMS ignored several of our asks related to Part D PBM pharmacy network contracting, including not finalizing a proposal to allow pharmacies to terminate Part D contracts without cause, and also requiring pharmacies to participate in the Medicare Drug Price Negotiation program via PBM contracts.
In other bad news, CMS did not finalize the requirement that Part D sponsors must alert pharmacies of network status by Oct. 1, 2025, and CMS did not grant NCPA's ask for a more detailed cost burden analysis impact on independent pharmacies.
In good news, the Medicare Transaction Facilitator will not charge dispensing entities any fees to use the system; CMS shortened the current 30-day window of time that Part D plan sponsors would have to submit Prescription Drug Event records from 30 days to 7 days; LTC pharmacy is required to provide the Likely to Benefit Notice at the time of cost-sharing billing; pharmacies are not required to inform beneficiaries of out-of-pocket costs under the Medicare Prescription Payment Plan (MPPP); and the 24-hour timeframe for election requests made during the plan year for MPPP is codified.
For details, see our member summary here.
