NASP weighs in on DIR fee reform in comments to CMS

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NASP weighs in on DIR fee reform in comments to CMS

By Sandra Levy - 01/30/2019
The National Association of Specialty Pharmacy has submitted extensive comments to the Centers for Medicare and Medicaid Services supporting Medicare Part D reforms that will lower out-of-pocket costs for beneficiaries, improve the transparency of fees, and improve the competitive market balance under the Medicare Part D program.

NASP's comments were in line with those recently provided by NACDS and NCPA in response to the CMS proposed rule, titled "Modernizing Part D and Medicare Advantage to Lower Drug Prices and Reduce Out-of-Pocket Expenses."

"The proposed rule includes needed regulatory adjustments related to direct and indirect remuneration, or DIR fees, and recognizes that current fees have resulted in substantial increased costs for seniors," said NASP executive director Sheila Arquette. "NASP supports CMS's efforts to reduce drug prices at the point of sale and stand up to a system that fairly and accurately assesses pharmacy performance, and we offer our analysis and recommendations on how to implement such reforms to specifically address the needs of specialty patients and the pharmacies that serve their needs."

Arquette also said, "We are so pleased the administration has recognized the extent to which DIR fees harm patients, Medicare, and the pharmacies that serve them. DIR, in its current form, has a disproportionate impact on independent specialty pharmacies. Now is the time for the administration to exercise its authority to amend regulation and implement these much-needed reforms."

In its comments, NASP advocates for CMS to finalize its proposal to amend the definition of negotiated price and move all pharmacy price concessions to the point of sale beginning in 2020, and simultaneously approve a standard set of metrics to fairly assess pharmacy performance based on the drugs dispensed and disease state being managed.

In addition to issuing comments on the rule, NASP joined the NCPA and NACDS in a letter to CMS urging action on the proposed reforms to move all pharmacy price concessions to the point of sale and to move toward a system of standardized quality metrics for pharmacies beginning in 2020. NASP also joined in a broader letter of support signed by 155 multi-disciplined stakeholders representing pharmacies and pharmacists. NASP and 62 other organizations sent a letter in coordination with the Pharmacy Quality Alliance, addressing the need to move forward with a standardized set of metrics to evaluate pharmacy performance.

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