Skeletons, ghosts, Frankenstein, yadda yadda yadda. You know what’s really frightening? The idea of a rulemaking defining reasonable and relevant Part D contract terms that doesn’t actually tackle PBMs’ bad behavior. Jokes aside, the recent request for information from the Centers for Medicare & Medicaid Services is our last shot at ensuring that the agency’s future rulemaking protects independent pharmacies from inadequate reimbursements and other abuses. It is absolutely essential that all independent pharmacy owners, regardless of practice setting, share their experiences with Part D and press the agency to rein in PBMs. Comments are due by 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. We’ve put together a template for you to modify with your pharmacy-specific details and made the submission process quick and simple.
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
This could be a real pivot point for independent pharmacies, but only if we forcefully make our argument for change. So go ahead and leave a comment — we promise it’ll be a real scream.
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.
