NCPA Provides Recommendations for Strengthening Medicare Part D

ALEXANDRIA, Va. (May 2, 2017) The National Community Pharmacists Association (NCPA) has submitted five recommendations for improving and transforming the Medicare Part D program in response to a Request for Information (RFI) from the Centers for Medicare and Medicaid Services (CMS). NCPA's input is based on the experiences of the independent community pharmacies NCPA represents, which on average see 35 percent of their dispensed prescriptions covered under Part D, according to the 2016 NCPA Digest, sponsored by Cardinal Health.

"The Medicare Part D program is vital to improving health outcomes for seniors, but it can and should be strengthened," said NCPA CEO B. Douglas Hoey, RPh, MBA. "NCPA's recommendations are intended to increase beneficiary access to pharmacies and make the program more financially sound. We're confident CMS will agree with our suggestions, and we look forward to helping in whatever capacity we can."

NCPA recommended that CMS:

• Finalize the concept included in 2014 proposed guidance on Direct and Indirect Remuneration (DIR) that sought to implement the new definition of "negotiated price" to include all pharmacy price concessions that can be reasonably estimated based on historical data;
• Issue guidance for Maximum Allowable Cost (MAC) drug pricing that requires MAC lists that are given to pharmacies be in an interactive spreadsheet format and require PBMs to establish a valid MAC appeals process;
• Establish access standards for preferred cost-sharing pharmacies or require plans to disclose in plan offerings and on Medicare Plan Finder the actual number of preferred pharmacies in each region;
• Address concerns about the implementation of the Comprehensive Addiction and Recovery Act (CARA) regarding the definition of frequently abused drugs, who is included in the list of exempted individuals, the standardization of notices about lock-in notices, and whether senior access to opioids will be unnecessarily compromised; and
• Assess the reliability of existing Pharmacy Quality Alliance (PQA) measures currently being used to determine performance at the pharmacy level.