The Centers for Medicare and Medicaid Services recently shared its proposed changes to Medicare Part D, and it includes several measures that the industry has been seeking. The proposed rule includes changes regarding e-prescribing and medication therapy management, addressing opioid abuse and building pharmacy access, the National Association of Chain Drug Stores said.
“NACDS was pleased to see progress on several important issues in CMS’ proposed rule – including pro-patient and pro-pharmacy approaches on which NACDS has advocated,” NACDS CEO Steve Anderson said. “NACDS will remain engaged on these topics and will issue further comments as CMS continues its work on this proposal, particularly where there are opportunities to shape policies to achieve even better results for Medicare beneficiaries and for the pharmacies that serve them.”
Among the measures in the proposed changes are implementations of guidelines from the comprehensive Addiction and Recovery Act of 2016, which treats a pharmacy with multiple locations that share real-time electronic info as a single pharmacy. By treating multiple locations as a single “locked-in” pharmacy — from which patients at risk for prescription drug abuse or misuse are required to pick up their medication by their plan sponsor, it allows for patient convenience, NACDS said.
CMS also is proposing the adoption of an official electronic prescribing standard for sharing electronic prescriptions and related information. The agency proposes adopting the National Council for Prescription Drug Programs SCRIPT Standard for electronic prescribing.
The proposed changes also take into account reimbursement for pharmacy services. It would classify MTM programs as a quality improving activity, rather than an administrative function — confusion over which NACDS said leads MTM to get included in an area on which Medicare Advantage plans limited spending to 15%. CMS also is clarifying that Part D plan sponsors can’t exclude pharmacies with innovative or unique models because they don’t fit the correct pharmacy type classification for contracted pharmacy networks.
Additionally, CMS is soliciting comments on potential policies relating to direct and indirect remuneration, or DIR, fees. NACDS said it would continue to push CMS to issue guidance calling for increased transparency on DIR Fees, particularly with regard to timing and consistency.
“NACDS will remain vigilant on the numerous, complex and highly consequential policies that ultimately affect pharmacy operations and pharmacy patient care. We will continue to articulate a pro-pharmacy and pro-patient voice as CMS advances its consideration of these issues, and we appreciate the progress that CMS is proposing on diverse and critical topics,” Anderson said.