Medicaid Program; Misclassification of Drugs, Program Administration and Program Integrity Updates Under the Medicaid Drug Rebate Program Comments

 The National Association of Specialty Pharmacy (NASP) welcomes the opportunity to provide comments in response to the Centers for Medicare and Medicaid (CMS) proposed rule, Medicaid Program; Misclassification of Drugs, Program Administration and Program Integrity Updates Under the Medicaid Drug Rebate Program. NASP is pleased to see CMS working to address spread pricing concerns in the Medicaid program and evaluating how specialty drug and pharmacy drug dispensing costs are captured in the rule. However, NASP encourages CMS to evaluate NASP’s comments on which pharmacies dispense specialty drugs and why there are unique considerations for the dispensing of these drugs (e.g., limited distribution networks) that determine when a specific pharmacy can be recognized for dispensing specialty drugs and also how to appropriately capture the cost of drugs that require special handling through a specialty pharmacy. We also wish to provide comments to raise concern over CMS’ proposal to require a diagnosis code on pharmacy orders. 

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