NCPA drafts letter to CMS in support of proposed DIR guidance
ALEXANDRIA, Va. -- The National Community Pharmacists Association and 21 other related stakeholder organizations earlier this week delivered a letter to the Centers for Medicare & Medicaid Services in support of proposed guidance that would provide greater transparency into direct and indirect remuneration (or DIR) fees and to provide additional suggestions on how these fees should be reported as the agency prepares to close the fiscal books on the 2015 plan year.
Specifically, this guidance would require Part D plan sponsors or their intermediaries, pharmacy benefit manager corporations, to report the money they receive from manufacturers separately from the money they receive from pharmacies. This will enable CMS to gain additional clarity into the sheer magnitude of the amounts of money that are being assessed on pharmacies. The letter submitted in response to this guidance is supportive and offers several suggestions to provide even greater clarity.
"DIR fees are confusing and misleading to pharmacies and beneficiaries alike," stated Douglas Hoey, NCPA CEO. "NCPA and others have long advocated for transparency around the fees," he said. "We encourage the agency to consider the recommendations we've offered for the 2015 plan year and to implement its previously proposed guidance for plan years 2016 and beyond."
Three specific recommendations were offered by the pharmacy organizations:
First, require plan sponsors to provide specific information regarding pharmacy fees and payments and what they represent, and explain why they cannot be reasonably estimated in advance;
Second, give plan sponsors additional examples of the kind of fees they should report, given the volume and variety of names the industry uses to describe such fees or payments;
Third, create an additional and separate reporting field to address the differences between the reimbursement rate initially indicated to the pharmacy at point-of-sale, and the "contracted" or "effective" reimbursement rate after fees or payments are applied.
The letter was signed by NCPA and the Academy of Independent Pharmacy (Georgia); American Pharmacy Cooperative; Astrup Drug; Burlington Drug Company; CARE Pharmacies Cooperative; Elevate Provider Network; Federation of Pharmacy Networks; Georgia Pharmacy Association; Independent Pharmacy Cooperative; Keystone Pharmacy Purchasing Alliance; Louisiana Independent Pharmacies Association; National Alliance of State Pharmacy Associations; Northeast Pharmacy Service Corporation; PBA Health; Pharmacy Productions (QualityCare Pharmacies); Philadelphia Association of Retail Druggists; PPOK RxSelect Pharmacy Network; Rochester Drug Cooperative; RxPlus Pharmacies; Smart-Fill Management Group; and the Southern Pharmacy Cooperative.
The letter also reiterated the importance for CMS to finalize its pending proposed guidance that would fully implement the new definition of "negotiated price" in Medicare Part D. This would ensure more consistent reporting from plan sponsors regarding DIR fees going forward. That guidance has received bipartisan support from Members of Congress, as evidenced by an October 2015 letter to CMS from 11 U.S. lawmakers.