CMS issues guidance on AWP compliance
BALTIMORE — The Centers for Medicare and Medicaid Services last week issued guidance to all Medicare Part D plan sponsors regarding the Part D program's “any willing pharmacy” requirement.
To comply with the AWP requirement, CMS stated that all Part D plans must have posted standard contracting terms and conditions associated with each plan by Sept. 15 of each year for the succeeding year's plans. For non-calendar year employer group waiver plans terms and conditions must be available 105 days prior to the implementation of the plan.
"For those terms to be reasonable and relevant, they must identify for the pharmacy the plan(s) to which they apply, and the offer must include language that obligates the Part D sponsor to include the pharmacy in the identified plan(s) upon the pharmacy’s acceptance of the terms and conditions," CMS wrote in its letter.
Those contracting terms and conditions also must include a way by which an interested pharmacy can contact the plan sponsor for inclusion into the plan and the plan sponsor must respond within two business days following Sept. 15.
"Because all sponsors should already have standard terms and conditions readily available by Sept. 15, there is no justification for a delay in responding to a pharmacy’s AWP request made after that date," CMS stated. "Therefore, sponsors should provide the applicable standard terms and conditions document to the requesting pharmacy within two business days of receipt of the request."
Early reactions to the new guidelines are optimistic, especially with regard to their potential impact on community pharmacy.
“This new guidance should help reduce the likelihood of repeating the debacle of early 2015 that affected approximately 400,000 Medicare beneficiaries, many caregivers and community pharmacists,” Douglas Hoey, CEO for the National Community Pharmacists Association, said. “Hopefully it will afford community pharmacists greater certainty and give patients more reliable information with which to select a drug plan, such as through the Medicare Plan Finder website.”