CMS Releases Request for Information: Medicare Part D Reasonable and Relevant Pharmacy Contracting Standards
On September 24, 2026, the Centers for Medicare & Medicaid Services (CMS) released a highly anticipated Request for Information (RFI) to begin implementation of the Medicare Part D pharmacy contracting reforms enacted by Congress earlier this year. The law requires CMS to establish standards to ensure that the terms and conditions offered to pharmacies seeking to participate in Medicare Part D networks are reasonable and relevant.
This marks an important next step for NASP and its members following our successful advocacy for the enactment of these protections. In the months leading up to the RFI, NASP has been actively engaging with CMS to help ensure the agency understands the unique contracting, reimbursement, and network access challenges facing specialty pharmacies and the potential impact these issues can have on their ability to provide comprehensive care to patients receiving complex therapies.
Of particular significance, CMS is seeking input on whether the agency should establish a definition of specialty pharmacy for Part D contracting purposes, as well as standards for determining which pharmacies qualify as specialty pharmacies. This is an especially important issue for NASP and its members, as any federal definition or eligibility standards could have far-reaching implications for specialty pharmacy network participation and patient access to specialty pharmacy services.
The RFI also seeks stakeholder input on several other critical issues, including:
- pharmacy reimbursement and dispensing fees;
- specialty pharmacy network participation;
- limited and exclusive specialty networks;
- contract transparency;
- quality and performance measures;
- audits; and
- other contracting practices.
Comments are due November 23, 2026, (60 days after publication in the Federal Register). NASP will be carefully reviewing the RFI and working with our members to develop comprehensive comments.
If you have any questions or concerns, please email advocacy@naspnet.org.