The Centers for Medicare & Medicaid Services issued a request for information soliciting public comments on what items constitute reasonable and relevant contract terms in Medicare Part D, which will inform future rulemaking on the issue. Comments will be due to CMS on Nov. 23.
The agency is requesting information on, among other things: pharmacy reimbursement and dispensing fees, current contracting practices, trends in contract terms and conditions, pharmacy quality and performance measures, auditing practices, and plan sponsor restrictions or limitations on the dispensing of covered Part D drugs.
NCPA is carefully reviewing the request and will share language soon that NCPA members can use when drafting their own comments for submission. It is extremely important that all independent community and LTC pharmacies take this opportunity to voice their experiences with Medicare Part D.
Congress mandated that CMS develop and enforce a definition for reasonable and relevant contract terms in a law passed earlier this year. You can learn more about the CMS rulemaking here, and the current request for information here.
