We’ve released a template to make responding to the CMS request for information on reasonable and relevant Medicare Part D contract terms much easier.
The CMS request for information on reasonable and relevant Medicare Part D contract terms is a landmark opportunity to make the program fairer to independent pharmacies, and we need all independent pharmacy owners, regardless of practice setting, to share their experiences with Part D. To make that easier, we’ve released a template you can use when submitting your comments on what CMS should require in Part D contracts — but it’s essential that you customize it with your own information before you submit it.
There are several items in the first paragraph that require your personalization prior to submission. Please be sure to include your information. If necessary, this information can be obtained from your PSAO or pharmacy management system vendor.
Tell CMS that, among other provisions, Part D contracts:
- Must require reimbursements that adequately cover ingredient acquisition costs as well as the actual cost to dispense
- Must have opt-in requirements for accepting contract terms
- Cannot link a pharmacy’s participation in a Part D plan to its ability to participate in other PBM networks
If you want to provide CMS more detail on your experiences, you can use a more in-depth template that NCPA will soon release that helps you include more specific information and data requested by the agency that is related to current Part D contracts. Contact NCPA’s Michael Rule at mrule@ncpa.org if you want to use that more detailed template.
