We have less than four weeks before the window to submit comments on the request for information on Part D contract terms closes. The Centers for Medicare & Medicaid Services is seeking public comment as the agency shapes a rule on what reasonable and relevant terms are, and we need all independent pharmacy owners, regardless of practice setting, to share their experiences with Part D and press the agency to protect independent pharmacies in the rule. We cannot afford to miss this once-in-a-lifetime opportunity to ensure contract terms are fair to independent pharmacies. We’ve put together a template for you to modify with your pharmacy-specific details and made the submission process quick and simple. Comments are due Nov. 23.
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 with more details on your experiences, you can use a more in-depth template that helps you include 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.
