ARLINGTON, Va. — The National Association of Chain Drug Stores has submitted extensive and thoroughly documented comments to the Centers for Medicare and Medicaid Services (CMS) in support of the agency’s proposal to reform direct and indirect remuneration (DIR) fees — reform that relates directly to reducing patients’ out-of-pocket drug costs.

NACDS issued its comments in response to CMS’ proposed rule titled “Modernizing Part D and Medicare Advantage to Lower Drug Prices and Reduce Out-of-Pocket Expenses,” which was released in ­November.

“The proposed changes are consistent with several of the administration’s priorities, including the goal to reduce prescription drug costs for patients, improve the Medicare program, and use [Department of Health and Human Services] programs to build a value-driven health care system,” NACDS wrote. “We therefore strongly urge CMS to use its current authority to further update the Part D Program by implementing these much needed reforms in the final rule.”

“NACDS members’ experiences confirm that the abuses and harms of pharmacy DIR fees are genuine,” the association added. “And the situation is rapidly growing worse, as abusive pharmacy DIR fees continue to grow exponentially. Pharmacies are calling on CMS to eliminate these and other harms now, by implementing reforms to eliminate pharmacy DIR fees.”

The comments say DIR fees are based on “a regulatory loophole that plans have exploited to increase beneficiary drug costs,” and that “CMS should close that loophole completely.”

NACDS has established DIR fee reform and related reimbursement issues as its top priorities.