NASP represents an industry that focuses on providing high quality patient care first with additional emphasis on clinical outcomes and patient choice. NASP believes that it shares these common goals with the Centers for Medicare & Medicaid Services (CMS) and looks forward to partnering with CMS and all governmental agencies to ensure that all patients have access to the medications they need from the pharmacy of their choosing. In furtherance of these shared goals, NASP has submitted the following comments in response to the Centers for Medicare & Medicaid Services’ (CMS) Proposed Rule entitled, “Medicare Program; Contract Year 2019 Policy and Technical Changes to the Medicare Advantage, Medicare Cost Plan, Medicare Fee-for-Service, the Medicare Prescription Drug Benefit Programs and the PACE Program” (Proposed Rule).
NASP urged the agency to address the following priority issues:
- Adopt NASP’s proposed definition of Specialty Pharmacy
- Consider pharmacy reimbursement in totality when moving pharmacy price concessions to the calculation of negotiated price, effective CY 2019.
- Codify and enforce that unreasonably low reimbursement rates, when offered in an initial network contract, occurring as a result of mid-year rate changes and/or after rebates/concessions are factored in to the final reimbursement rate subverts the convenient access standards.
- Finalize its proposals to the Any Willing Pharmacy (AWP) changes while providing greater clarity on how the agency plans to enforce these changes.
- Tweak the definitions of retail and mail order pharmacy; and,
- Survey specialty pharmacies as part of the agency’s efforts to gain a better understanding of the quality of care being provided under the Medicare Part D program.