CMS put PBMs on notice in a recent memo on the Medicare Drug Price Negotiation Program (MDPNP). See below for some key highlights from the memo.
Fair reimbursement: CMS stated that it continues to hear concerns that pharmacies fear reimbursement from the Part D plan plus the manufacturer refund might be below the price the pharmacy paid to acquire the selected drug, including potentially below the maximum fair price (MFP) for the selected drug. CMS will closely monitor whether further programmatic adjustments are needed.
Dispensing fees: CMS stated that it expected Part D plan sponsors' dispensing fees to sufficiently compensate network pharmacies so that enrollees can be assured network access to selected drugs. CMS stated that examples of pharmacy costs that can be included within the dispensing fee are salaries, time associated with checking for coverage, filling the container, packaging, and overhead (including IT).
Network adequacy: Finally, CMS reminded all Part D plan sponsors of the network adequacy requirements for contracted pharmacies.
For resources and NCPA's advocacy on the MDPNP, see here.
