This week NCPA and our partners in the Pharmacy Coalition met with CMS officials to continue discussions surrounding implementation of reasonable and relevant contract terms between PBMs and pharmacies in Medicare Part D networks. CMS is working to develop these contract terms and will soon release a Request for Information seeking input on items that constitute reasonable and relevant terms. NCPA will be alerting members when the RFI is released and will offer members a template to submit individual comments. It is extremely important that all independent pharmacies take this opportunity to voice their experiences with Medicare Part D.
The coalition previously submitted a memo to CMS, seeking to ensure that its authority operates without limitation from the Part D noninterference clause. The coalition has also submitted a memo to CMS outlining a non-exhaustive list of concrete examples of problematic practices we’re seeing in Part D contracting today. We will maintain a dialogue with the agency as this important work continues. Pharmacies will begin to see contracts containing the new standards in 2028, with an effective date of Jan. 1, 2029.
The Pharmacy Coalition is comprised of NCPA, the National Association of Chain Drug Stores, American Pharmacists Association, FMI – The Food Industry Association, National Association of Specialty Pharmacy, and American Society of Consultant Pharmacists.
