AmerisourceBergen has long supported greater transparency on DIR fees and having them assessed at point of sale rather than retroactively. In early April, the industry received news from CMS regarding their statutory authority to require that some portion of rebates and pharmacy DIR fees be applied at point of sale. NCPA shared an update on their website, included below.
NCPA Update on New Part D Rule
In a 1,000-page final 2019 Medicare Part D rule released Monday afternoon, the Centers for Medicare & Medicaid Services asserted its statutory authority to require that some portion of rebates and pharmacy DIR fees be applied at point of sale. The final rule stops short of actually requiring such a change, instead stating that "any new requirements regarding the application of rebates at the point of sale would be proposed through notice and comment rule-making in the future."
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CMS' recognition of the need to address the issue at all is largely the result of NCPA's forceful lobbying and input.
The final rule also reflects NCPA's input on a handful of other Part D issues important to community pharmacists, including:
• Reiterating any willing pharmacy requirements in standard plans, which clarifies that plan sponsors cannot exclude pharmacies with unique or innovative business or care delivery models from participating in their contracted pharmacy network.
• Clarifying that Part D plan sponsors cannot use certain network accreditation policies to limit dispensing of certain drugs or drugs for certain disease states to a subset of network pharmacies.
• Requiring Part D plan sponsors to develop standard terms and conditions and make them ready for distribution by Sept. 15. A pharmacy must request the applicable standard terms and conditions and the plan sponsor must provide them to the pharmacy within seven business days of receipt of request.