Based on insights from member pharmacies that serve as the front lines of healthcare delivery, the National Association of Chain Drug Stores (NACDS) has submitted extensive and thoroughly documented comments to the Centers for Medicare & Medicaid Services 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’ comments respond to a CMS proposed rule released in November 2018.
- DIR fees are being misused by payers to claw back reimbursement paid to pharmacies for prescriptions filled for Medicare beneficiaries.
- Payers penalize pharmacies for alleged failure to reach benchmarks – many of which are vague, undefined, inconsistent, unachievable or outside of the control of pharmacies.
- Interpretations of specific terms used in Medicare have led to these claw-backs, to higher out-of-pocket drug costs for patients, and to increased healthcare costs overall.
- NACDS describes: the harm of current DIR practices; support for DIR fee reform and for a properly-aligned pharmacy quality incentive program; ways that reform would reduce patients’ out-of-pocket drug costs and overall healthcare costs; and CMS’ authority to act.