NCPA and NACDS submitted joint comments to CMS on its proposed rule governing Medicaid managed care state-directed payments and fee-for-service targeted Medicaid practitioner payments. The proposal is intended to strengthen Medicaid fiscal integrity, but without clarification, it could unintentionally affect how states reimburse pharmacies and pharmacists for Medicaid-covered services.
Together, we urged CMS to clarify that standard Medicaid pharmacy reimbursement, including ingredient cost reimbursement, professional dispensing fees, and other pharmacy benefits, falls outside the scope of the proposed rule. We also emphasized that states must retain flexibility to reimburse pharmacists for the growing range of health care services they provide to Medicaid beneficiaries, including immunizations, test-and-treat services, medication therapy management, and other patient care services.
Additionally, the letter asks CMS to ensure the final rule does not discourage state innovation or create unnecessary barriers to pharmacy participation in Medicaid. The letter recommends clarifying that broadly available payment methodologies for qualified pharmacies and pharmacists are not considered "targeted" payments and should remain available to support patient access, quality, and value-based care initiatives.
You can read the comment letter here.
