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Respond to CMS’ RFI to Change the Part D Payment Model
As you are aware, CMS recently released its long-awaited request for information (RFI) regarding Part D reasonable and relevant contract terms. CMS is seeking public comment, and we need all independent pharmacy owners, regardless of practice setting, to submit comments.

 

IPC is joining NCPA in making it easy for you to make your voice heard and offer recommendations on provisions CMS should require in Part D contracts. Click here to submit your comments. Please note, 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

In addition to this opportunity, NCPA is creating a more detailed template that pharmacies can submit to provide specific information related to current Part D contracts that has been requested by CMS. 

Please contact Michael Rule at mrule@ncpa.org with NCPA if you would like to submit more the in-depth comments. Note, this will require specific details on your part, but NCPA can assist you with the template and instructions on how to upload your comment letter to the docket on regulations.gov.

IPC is joining NCPA who will be submitting detailed comments on behalf of independent community and LTC pharmacies.

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