NCPA weighs in on proposed CMS DIR fee guidance

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NCPA weighs in on proposed CMS DIR fee guidance

By David Salazar - 06/02/2017

WASHINGTON — In mid-May, the Centers for Medicare and Medicaid Services released a proposed guidance on Medicare Part D reporting requirements for direct and indirect remuneration fees. The National Community Pharmacists Association on Thursday submitted to CMS a letter with comments about the proposed guidance. The organization notes that there is some promise in the guidance. 


Among the measures NCPA applauded was a change in how DIR fee information is collected with regard to distinguishing between prices concession that pharmacies received and incentive payments to pharmacies from Medicare Part D sponsors. It also commended CMS for including the organization’s previous suggestion for Medicare Part D plan sponsors to detail the metrics by which they assess pharmacy performance. 


“While the proposed CMS guidance will not change existing policy with regard to DIR fees, it does have the potential to require plans to provide greater granularity to CMS on DIR amounts and the types of arrangements they put into place,” NCPA CEO Doug Hoey said. “The agency has responded positively to many of our previous recommendations, and even issued an analysis showing the financial havoc retroactive pharmacy DIR fees are causing patients, taxpayers, and pharmacies. We urge CMS to consider our latest suggestions on reporting by plan sponsors.”


Among things NCPA would like CMA to address is the need to finalize the agency’s 2015 DIR report on DIR and pharmacy price concessions. It also suggested that CMS include more categories to require plan sponsors to further define the amount of DIR fees charged to non-retail pharmacies, and called for CMS to require Medicare Part D plan sponsors to justify why DIR fees can’t be estimated at the point of sale. 


“NCPA remains committed to ending retroactive pharmacy DIR fees by passing S. 413 / H.R. 1038, the Improving Transparency and Accuracy in Medicare Part D Drug Spending Act,” Hoey said. “However, we’re also committed to working with CMS to provide clarity on DIR fees as they currently exist via the regulatory process.”


To read the full guidance, click here, and to read the full text of NCPA’s comments, click here