Health Policy Check Up News

CMS Releases 2019 Medicare Part D Final Rule Addressing Important Issues for Pharmacies

On April 2, 2018, the Centers for Medicare and Medicaid Services (CMS) released the 2019 Medicare Part D Final Rule. The Final Rule addresses several Medicare Part D issues of importance to the community pharmacy industry, including:

  • Direct and Indirect Remuneration (DIR)
  • Standard terms and conditions
  • Accreditation
  • Comprehensive Addiction and Recovery Act (CARA) Implementation
  • Any Willing Provider
  • Part D Formulary Changes
  • Part D Tiering Exceptions
  • Mail Order Definitions
  • The interpretation of retail pharmacy networks

The Medicare Part D Final Rule presents many legal and policy options that can be used to argue against several issues that pharmacies confront with Pharmacy Benefit Managers (PBMs) and plan sponsors, including network participation, credentialing, and reimbursement changes based on dispensing history. Contact Frier Levitt Government Affairs today for help with the Final Rule.