Pharmacists Must Stay Knowledgeable on Evolving IRA Provisions | NCPDP 2025
Greg Miller, RPh, discussed the past, present, and future of the Inflation Reduction Act and key insights pharmacists should understand in order to keep up with the legislation.
It’s important for pharmacists to stay knowledgeable on the ongoing changes and provision updates of the Inflation Reduction Act (IRA). Changes to the IRA have occurred every year since its inception in 2022, forcing independent and retail pharmacy owners to stay updated on IRA changes that will impact pharmacy profit, medication access, and so much more.
“When you think about it from a plan and PBM implementation standpoint, a lot has happened. Keep in mind, this all came about when the law was signed in 2022,” said Greg Miller, RPh, at the National Council for Prescription Drug Programs (NCPDP) 2025 Annual Conference, held May 5 to May 7 in Scottsdale, Arizona.1 “Think about the time frame as we go through here, and how much work has been done by a lot of you folks in the room, your colleagues, peers, all the folks here at NCPDP. A lot has changed, a lot has been done, to get this IRA into implementation from an adjudication standpoint.”
A lot has changed within the drug supply chain since implementation of the IRA, from the year it was introduced to drug price negotiations taking effect in 2026. | image credit: may1985 / stock.adobe.com
Indeed, from the year the IRA was introduced to drug price negotiations taking effect in 2026, a lot has changed within the pharmaceutical industry since implementation of the IRA. In October of 2022, the first key IRA provision for Medicare Part D beneficiaries went into effect, forcing manufacturers to pay Medicare rebates if drug prices increased faster than the rate of inflation.2
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Insulin cost-sharing then rolled around in 2023, creating a $35 monthly cap on insulin supplies for Part D beneficiaries. They were also provided no cost-sharing for immunizations, making all vaccines approved by the Advisory Committee on Immunization Practices free. Then in 2024, average premium increases were capped at 6%, a low-income subsidy program was introduced, and Part D drug price negotiations were announced.
“There's a window of opportunity that it will be interesting to see the adoption in the beginning of 2025 because now we have in place, we have some control of the data,” continued Miller.1 “So, when we start to look at the year-over-year comparisons from building out, well, we didn't have a lot of people last year and we don’t have a lot of people this year. What's going on? Is there an educational thing? The program is implemented now. By and large, unless there's some other congressional acts, this is going to be the process.”
As Miller stated, the first 3 years of the IRA leading up to 2025 were intended to gradually provide a variety of cost savings for Part D beneficiaries. Part B drugs were also involved in the first 3 years, creating further cost savings as the legislation underwent various, year-by-year processes. Now, with the real-world data of how beneficiaries are participating in these newly formed plan designs, players within the pharmaceutical industry have a better idea of how to facilitate their businesses amid the dynamic IRA legislation.
Miller then looked ahead, detailing IRA provisions in 2025 and beyond as well as the drug price negotiations set to take effect next year.
The first 10 drugs chosen for Medicare price negotiations—announced in August 2024—included several drugs to treat disease states like diabetes and heart failure, among others. With previous prices that deemed many of these medications as ultra-high-cost drugs, Miller expects a similar trend to follow as glucagon-like peptide-1s (GLP-1s) increase in popularity and demand. He believes that these weight-loss drugs will almost certainly be included in future Medicare drug price negotiations.3
Finally, he touched on the importance of compliance amid all these ongoing IRA changes. For all drug supply chain entities, compliance is crucial and Miller provided insights into the best and easiest ways of abiding by IRA regulations. With much of it going back to the secure management of prescription drug event data,4 staying compliant can be as simple as establishing proper communications with Centers for Medicare and Medicaid (CMS) representatives and being prepared for government audits.
“Continue to monitor IRA elements that have already been implemented,” concluded Miller’s presentation.1 “Develop [and] update policies and procedures as needed.” To stay up to date on compliance and IRA changes, “participate in industry work groups and comment periods.”
Read more from our coverage of NCPDP 2025.
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