NASP Submits Comments on the CY 2027 Physician Fee Schedule Proposed Rule
NASP submitted comments to CMS on the CY 2027 Physician Fee Schedule Proposed Rule, focusing on proposed changes to 340B reporting requirements. NASP expressed concern about CMS’s proposal to make reporting to the Medicare Part D Claims Data 340B Repository a mandatory Medicare enrollment requirement and the operational challenges it could create for specialty pharmacies.
NASP called on CMS to take a practical approach to implementing the new reporting requirements, giving specialty pharmacies sufficient time, guidance, and flexibility to build compliant reporting processes. NASP also emphasized the need for a clear pathway to correct reporting errors and for CMS to prioritize education and corrective action before pursuing Medicare enrollment sanctions. These recommendations seek to improve the accuracy of 340B reporting without creating unnecessary administrative burden or jeopardizing patient access to specialty pharmacy care.