NACDS Voices Support for CMS Pharmacy Quality Proposal


CMS proposed taking action to increase transparency in Medicare Part D plan sponsors’ pharmacy performance measures.

Drug Prices

NACDS is welcoming “the strongest signal yet” by the Centers for Medicare & Medicaid Services (CMS) that a standardized pharmacy quality program should be created.1

In a new proposed rule, CMS proposed taking action to increase transparency in Medicare Part D plan sponsors’ pharmacy performance measures, NACDS said in a press release.1,2 Plan sponsors would have to disclose these measures and CMS would publish them, according to the proposal.2

The CMS rule also recommends principles to guide pharmacy performance measures, urges the industry to work together toward appropriate measures, and indicates the possibility that CMS may incent plans to use appropriate quality measures, NACDS said.1

Under the current system, quality measures that often are unknown, unpredictable, inconsistent, and beyond a pharmacy’s control are figuring significantly into direct and indirect renumeration (DIR) fees, NACDS said.2

“This is a positive and welcome development from CMS, and we urge the agency to continue to move toward a requirement for a standardized pharmacy quality program,” NACDS President and CEO Steven C. Anderson, IOM, CAE, said in a statement.2 “Now, given the dire situation facing pharmacies and the patients they serve, NACDS also urges Congress to act on this momentum and to advance DIR fee relief in a legislative vehicle this year.”

DIR fee relief includes a standardized pharmacy quality program and prevention of retroactive ‘clawbacks’ of pharmacy reimbursement to reduce patients’ out-of-pocket drug costs and to help patients maintain critical access to their pharmacies, Anderson said.2

CMS previously found that DIR fees exploded by 45,000% in recent years. NACDS–along with several other organizations–lauded progress on the inclusion of essential DIR fee relief components in the bipartisan Prescription Drug Pricing Reduction Act.2

“The legislation in its current form would establish standardized pharmacy quality measures and would address clawbacks,” NACDS said.2

The bill represents a “potentially major reform that would generate savings and create pricing transparency for pharmacy patients,” a coalition that includes NCPA, NACDS, American Pharmacists Association, and several other pharmacy groups said in a statement in December. “It would put a stop to the predatory practice of imposing fees on pharmacies long after the point of sale and charging patients more up front for their drugs.”

The coalition also includes the American Society of Consultant Pharmacists, National Association of Specialty Pharmacists, Food Marketing Institute, National Grocers Association, American Pharmacists Association, and the National Alliance of State Pharmacy Associations.


1.    Medicare Proposed Rule Fuels Push for Standardized Pharmacy Quality Program [news release]. NACDS’ website.

2.    Centers for Medicare & Medicaid Services. Medicare and Medicaid Programs; Contract Year 2021 and 2022 Policy and Technical Changes to the Medicare Advantage Program, Medicare Prescription Drug Benefit Program, Medicaid Program, Medicare Cost Plan Program, and Programs of All-Inclusive Care for the Elderly [proposed rule]. Federal Register.


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