NCPA submitted comments to the Pharmacy Benefit Management Working Group of the National Association of Insurance Commissioners in response to their new draft chapter of the NAIC market conduct manual, which includes standards for PBM examinations. NCPA commented on a range of standards pertaining to the relationship between PBMs and pharmacies, including transparency for dispensing fees, policies for effective rates, dispute resolution and appeals procedures, access to PBM claims data, and pharmacy audits.
Across all proposed standards, NCPA urged stronger enforcement policies. In addition to recommendations about examination standards, NCPA urged NAIC to make retail pharmacy experience a standard for the PBM examiners, citing pharmacists' unique qualifications to understand pharmacy operations, the relationship and dynamics between PBMs and pharmacies, and the impact of policy on patient care.
Read the comments here.