One week ago today, when the Federal Register posted the Covered Outpatient Drugs Final Rule – or as we tend to call it, the Medicaid AMP rule – it set off a chain of events that the founders of NACDS envisioned 83 years ago.

On pivotal issues that affect pharmacy patient care, NACDS members are stronger when united together.

The members and staff of NACDS began to dissect the rule with the same spirit that has guided NACDS’ advocacy on this issue over the past decade and that led to the very creation of NACDS: that on pivotal issues that affect pharmacy patient care, NACDS members are stronger when united together.

I hope you saw the historical timeline of this issue, which led us to the posting of the final rule. But right now I want to focus on the tremendous amount of work that has been underway over just the past week:

  • The NACDS Policy Council and NACDS staff experts are discussing the intricacies of the rule and various interpretations of the provisions’ real-world effects on pharmacy patient are.
  • Legal counsel – external, internal to NACDS, and advisors to NACDS member companies alike – are developing their professional analyses of the rule.
  • We are engaging with pro-pharmacy and pro-patient champions on Capitol Hill who have been integral to these issues.
  • Economic and industry experts within NACDS member companies and on the NACDS staff are running numbers associated with the rule.
  • NACDS is reaching out to the Centers for Medicare & Medicaid Services to ask for clarifications, such as those related to the implementation dates of the federal upper limits – on which questions have arisen based on the reading of the rule.
  • NACDS is serving as a trusted resource to the media, which are seeking expert insights on the rule’s policy, process and context.
  • We are focusing on clear and consistent member communications and conference programming that will facilitate thorough discussion, understanding and direction from the membership on NACDS’ future course of action related to these issues.
  • We also are collaborating with allies, including the National Community Pharmacists Association, in the same spirit that has led to effective advocacy over the past ten years – including the successful litigation that blocked the prior AMP rule to implement the related provisions of the Deficit Reduction Act of 2005.


This process will continue to play out over the next several weeks, including a thorough discussion of these issues during the NACDS Regional Chain Conference that begins February 7.

This is the unified approach to blocking and tackling that is essential to association leadership, and that the very first leaders of NACDS wisely sought eight decades ago.