5 Ways to Improve Medicare Part D

May 3, 2017

NCPA’s recommendations for improving the “increasingly complicated Part D marketplace.”

The National Community Pharmacists Association (NCPA) recently sent a letter to CMS, detailing five recommendations that they hope will improve Medicare Part D.

The letter came in response to the CMS’ Request for Information (RFI), which asks for the submission of ideas to accomplish goals of “using transparency, flexibility, program simplification and innovation to transform the MA and Part D programs.” NCPA

Douglas Hoeytook the opportunity to provide their recommendations designed to help pharmacists help seniors “navigate the increasingly complicated Part D marketplace.”

“The Medicare Part D program is vital to improving health outcomes for seniors, but it can and should be strengthened,” said NCPA CEO B. Douglas Hoey, RPh, MBA, in a press release. “NCPA’s recommendations are intended to increase beneficiary access to pharmacies and make the program more financially sound. We’re confident CMS will agree with our suggestions, and we look forward to helping in whatever capacity we can.”

Related article: Pharmacy education and provider status

The NCPA recommends that CMS:

  • Finalize the concept included in 2014 proposed guidance on direct and indirect remuneration (DIR) that sought to implement the new definition of “negotiated price” to include all pharmacy price concessions that can be reasonably estimated based on historical data

  • Issue guidance for maximum allowable cost (MAC) drug pricing that requires MAC lists that are given to pharmacies be in an interactive spreadsheet format and require PBMs to establish a valid MAC appeals process

  • Establish access standards for preferred cost-sharing pharmacies or require plans to disclose in plan offerings and on Medicare Plan Finder the actual number of preferred pharmacies in each region

  • Address concerns about the implementation of the Comprehensive Addiction and Recovery Act (CARA) regarding the definition of frequently abused drugs, who is included in the list of exempted individuals, the standardization of notices about lock-in notices, and whether senior access to opioids will be unnecessarily compromised

  • Assess the reliability of existing pharmacy quality alliance (PQA) measures currently being used to determine performance at the pharmacy level.

According to an NCPA study sponsored by Cardinal Health, 35% of prescriptions filled by independent community pharmacies.