After years of advocacy, CMS is finally crafting a PBM reform rule defining “reasonable and relevant” Medicare Part D contract terms. Now is our one chance to make sure that rule’s contents reflect the experiences of independent pharmacies with Part D. We need all independent pharmacy owners, regardless of practice setting, to share their experiences and press the agency to protect independent pharmacies by the Nov. 23 deadline.
We’ve 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 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 related to current Part D contracts. Contact NCPA’s Michael Rule at mrule@ncpa.org if you want to use that more detailed template.
