NCPA submitted comments to the Centers for Medicare & Medicaid Services (CMS) on its calendar year 2027 proposed rule on Medicare Part D and Medicare Advantage (MA).
In the comments, NCPA asked CMS to:
Explore new reimbursement models in stand-alone and MA prescription drug plans that compensate long-term care pharmacies (LTCPs) for their value-added services, e.g., clinical expertise, medication management, drug delivery, compliance packaging, 24/7 availability, and collaborative care efforts;
Finalize a previous proposal which would require all Part D sponsors, including all first tier, downstream, or related entities (FDRs), to notify network pharmacies which plans will be in-network prior to October 1 of the year prior to the upcoming plan year; and
Clarify if current regulations allow CMS to open special election periods for redoing networks in the event that PBMs and plans provide false information.
Additionally, NCPA urged CMS to leverage pharmacies in Medicare to reduce harmful chronic diseases in America, including by asking CMS to:
Formally recognize pharmacists as providers to claim reimbursement under Medicare Part B
Expand pharmacists' role in medication therapy management in Medicare Part D
Address challenges for pharmacists and pharmacies to deliver diabetes self-management training services
Allow pharmacists to bill for the device unit and the corresponding counseling of continuous glucose monitoring in Medicare
Allow Annual Wellness Visits to be delivered under general supervision
NCPA also joined a group of 55 other signatories in submitting comments to CMS on this proposed rule on behalf of LTC pharmacies.
