NASP’s Comments on the Centers for Medicare and Medicaid Services’ (CMS) proposed regulation

The National Association of Specialty Pharmacy (NASP) is pleased to represent the entire spectrum of the specialty pharmacy industry from the nation’s leading independent specialty pharmacies and practicing pharmacists to small and mid-size pharmacy benefit managers (PBMs), pharmaceutical and biotechnology manufacturers of specialty drugs; group purchasing organizations; wholesalers and distributors; integrated delivery systems and health plans; and technology and data management companies.

NASP has submitted the following comments on the Centers for Medicare and Medicaid Services’ (CMS) proposed regulation, “Modernizing Part D and Medicare Advantage to Lower Drug Prices and Reduce Out-of-Pocket Expenses” [83 Fed. Reg. No. 231, November 30, 2018; CMS-4180-P; RIN 0938-AT92).

In appreciation of the agency’s clear interest in moving pharmacy price concessions to the point-of-sale and addressing claw back DIR fees that pharmacies face in order to lower out-of-pocket costs for Medicare Part D beneficiaries, improve the transparency of fees, and ensure competitive balance under the Medicare Part D program, NASP engaged in an extensive process to obtain all stakeholder input through active collaboration with the NASP Executive Committee, Board of Directors, Government Affairs Committee members and ad hoc work groups in addition to other pharmacy associations including NCPA, NACDS, and PQA to most effectively articulate our comments, concerns and recommendations.

NASP looks forward to continuing to work with CMS and the Office of the Secretary and on your behalf, to support policy reforms that will reduce costs to Medicare beneficiaries and the broader Medicare program for specialty drugs and ensure access to the specialty drugs and services needed to improve health and reduce overall healthcare costs.

Please click here to review our comments in their entirety

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