ALEXANDRIA, Va. — In comments submitted to the Centers for Medicare & Medicaid Services, the National Community Pharmacists Association is urging the agency to utilize a wide scope under its authority to collect information related to how pharmacy “performance” is measured in Medicare Part D to help address problems independent pharmacies are facing in serving Part D patients.

Pharmacy quality measurement in the Part D program is tied to pharmacy benefit manager recoupments from the pharmacy after the point of sale, as opposed to being a standardized quality payment program. Plan sponsors are receiving significant bonus payments for their performance, yet bonus payments are not being passed down to providers to drive performance. Especially with plan sponsors receiving bonus payments, NCPA says, community pharmacists should be rewarded for efforts to drive performance and not solely penalized with price concessions after the point of sale, which are often referred to as direct and indirect remuneration fees. CMS itself previously acknowledged that pharmacy DIR fees assessed against pharmacies participating in Medicare Part D plans grew by 45,000 percent from 2010 to 2017.

NCPA issued the following statement from Ronna Hauser, vice president of Policy and Government Affairs Operations:

“Quality measures being applied to independent pharmacies by plans and PBMs were often developed for use in population health measurement at a health plan level, not for pharmacies with smaller numbers of patients. Added to their limited insight into their own quality standing and metrics, community pharmacies are left holding the bag as PBMs extract billions of dollars in pharmacy DIR fees. We’re pushing CMS in these comments and elsewhere to modernize the reporting system, require the plans and PBMs to provide as much specifics as possible on the measures used in determining pharmacy DIR fees, and identify potential issues across the variance of measures used by the plans. These are crucial changes for independent pharmacies and the patients they serve.” 

Click here for NCPA’s comments to CMS.