The Centers for Medicare & Medicaid Services is looking for public input as it shapes a rule on reasonable and relevant Medicare Part D contract terms. This is a once-in-a-lifetime chance for independent pharmacies to influence how the agency regulates the program. Simply put, we cannot afford to miss this opportunity to ensure contract terms are fair to independent pharmacies. We need all independent pharmacy owners, regardless of practice setting, to share their experiences with Part D. To make it easier, we put together a template for you to modify with your pharmacy-specific details and made the submission process quick and simple.
It’s important that you personalize the comment that you submit; if necessary, you can obtain the relevant information 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
- Must prohibit reconciliations that reduce payment after a claim is paid
You can find the template here.
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.
