CMS Releases RFI on Part D Pharmacy Contracting Standards

DATE: September 24, 2026

Yesterday, CMS released a new Request for Information (RFI) seeking input on how it should establish “reasonable and relevant” pharmacy contracting standards in Medicare Part D, as required by the Consolidated Appropriations Act, 2026 (CAA). The new standards will apply beginning in plan year 2029.

Importantly for long-term care (LTC) pharmacy, the RFI specifically asks commenters to consider how contracting and reimbursement issues may differ by pharmacy type, including LTC pharmacy. While the CAA identified broad areas for CMS to examine, the RFI asks detailed questions about how those issues operate in practice.

Many of these questions align closely with issues SCPC has been raising with CMS and Congress, including appropriate reimbursement for the LTC pharmacy model, contracting transparency, negotiating leverage, and recognition of the distinct services and costs associated with LTC pharmacy.

Some key issues for LTC pharmacies include:

• Reimbursement & dispensing fees:Whether payments adequately cover pharmacy acquisition and operational costs.
• Potential reimbursement standards:Whether CMS should establish reimbursement methodologies or rates as part of the new standards.
• Contracting practices: Pharmacy negotiating leverage, contract transparency, amendments, and network participation.
• Disputes & audits: Dispute resolution, termination, audits, and recoupments.
• PBMs & PSAOs: Their role and impact in Part D pharmacy contracting.
• Different pharmacy models: How contracting terms and quality measures affect LTC and other pharmacy types differently.
• Maximum Fair Price (MFP)/Inflation Reduction Act (IRA) implementation: How Medicare drug-price negotiation is affecting pharmacy reimbursement and contracting.

SCPC will be reviewing the RFI closely and working with the Policy Committee and members to develop comments, building on our previous comments to CMS on these issues, to ensure the unique needs and operational realities of LTC pharmacies are appropriately reflected as CMS develops the new standards.

Comments are due November 23, 2026.