Reference Library

Advocacy Documents

The National Association of Specialty Pharmacy (NASP) filed an amicus brief on March 2, 2020, in support of the case going before the Supreme Court on April 27, 2020 to decide on states’ rights to regulate pharmacy benefit managers (PBMs). The case Rutledge v. the Pharmaceutical Care Management Association (PCMA) will determine whether states can regulate pharmacy reimbursement, overseeing PBM practices, or whether the Employee Retirement Income Security Act (ERISA) preempts states from regulating such practices.

NASP’s Comments on the Office of Inspector General (OIG) Department of Health and Human Services (HHS) proposed regulation, “Fraud and Abuse; Removal of Safe Harbor Protection for Rebates Involving Prescription Pharmaceuticals and Creation of New Safe Harbor Protection for Certain Point-of-Sale Reductions in Price on Prescription Pharmaceuticals and Certain Pharmacy Benefit Manager Service Fees” [84 Fed. Reg. No. 25, February 6, 2019; OIG-0936-P; RIN 0936-AA08].

NASP’s Comments on 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).

NASP’s Comments on the HHS ANPRM on the IPI Model for Medicare Part B Drugs

NASP’s Comments on HHS Blueprint & Request for Information

A Tangled Web – An Examination of the Drug Supply and Payment Chains

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

Announcement of Calendar Year (CY) 2019 Medicare Advantage Capitation Rates and Medicare Advantage and Part D Payment Policies and Final Call Letter

CMS Finalizes Policy Changes and Updates for Medicare Advantage and the Prescription Drug Benefit Program for Contract Year 2019 (CMS-4182-F)

2019 Medicare Advantage and Part D Rate Announcement and Call Letter

NASP’s Comments to CMS’ Proposed Rule and 2019 Draft Call Letter

NASP submits comments to CMS on Medicare Proposed Rule for Contract Year 2019

CMS Proposed Rule on Part D – November 16th, 2017

NASP’s comments to CMS’ Proposed Medicare Part D DIR Reporting Requirements for 2016

NASP Response to the 2017 Transformation Ideas in Response to Final Part D Call Letter’s Request for Information (RFI)

NASP Response Advance Notice of Methodological Changes for Calendar Year (201) for Medicare Advantage (MA) Capitation Rates, Part C and Part D Payment Policies and 201 Call Letter

Any Willing Pharmacy (AWP) Changes Are Needed to Improve Beneficiary Access to Specialty Pharmacies

Overview of AWP Provisions for 2017 Contract Year

Overview of 2017 Direct and Indirect Remuneration Fees

DIR Fees Increase Medicare Beneficiary and Medicare Program Costs for Specialty Drugs

NASP Definitions of Specialty Pharmacy and Specialty Medications

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