NASP White Paper: “Performance” Based DIR Fees: A Rigged System with Disparate Effect on Specialty Pharmacies, Medicare Part D Beneficiaries and the U.S. Healthcare System

On behalf of National Association of Specialty Pharmacy, the Executive Board commissioned a white paper (Performance” Based DIR Fees: A Rigged System with Disparate Effect on Specialty Pharmacies, Medicare Part D Beneficiaries and the U.S. Healthcare System), authored by the law firm, Frier Levitt, LLC. We write to you to make you aware of the enclosed white paper and forthcoming press release. Please review the document in detail to better understand the background and implications of DIR fees.

The white paper focuses on percentage-based DIR fees which are often shrouded by PBMs under the aegis of “performance.” However, as the white paper demonstrates, the performance metrics used by PBMs are wholly inapplicable to the unique and high-touch services provided by specialty pharmacies, leaving them no meaningful opportunity to actually influence the performance scores being assessed against them. Instead, these DIR fees do nothing to improve performance for specialty pharmacy patients served by Medicare Part D and Medicare Advantage pharmacy networks, and amount to nothing more than an “after-the-fact” surcharge on providers, often putting them grossly underwater on high-priced specialty medications and threatening their ability to continue to provide life-saving services to support Medicare beneficiaries with diseases treated by specialty medications.

We understand that you may receive questions from your colleagues and from media. Please forward all media inquiries to Sheila Arquette at (703) 842-0122 or sarquette@NASPnet.org.

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