WVPA requests CMS act on Medicare programs

In a December letter to federal Centers for Medicare and Medicaid Services (CMS) WVPA Executive Director Richard Stevens expressed strong support of the agency’s proposed rules requiring all price concessions from pharmacies (pharmacy DIR Fees) be reflected in the negotiated price that is made available at the time a medication is dispensed.

Stevens wrote, “This approach will provide CMS with greater transparency, enhance pharmacies’ predictability of business operations and lead to beneficiary savings.”

Currently, DIR fees are assessed retroactively, often weeks or even months after a prescription has been filled.   According to Stevens, this creates uncertainty for the pharmacy as to what its net reimbursement for dispensing a medication will be.  Current delay imposes unnecessary burdens on pharmacy operators as they assess their ability to invest in and grow their small business pharmacies.

If CMS requires all pharmacy price concessions to be accounted for at point-of-sale, PBMs would still maintain the ability to create quality-based incentives that reward pharmacies for achieving contractual, performance-based metrics.