SCPC Provides Comments on CMS Proposed Rule Regarding Medicare Program
Dear Administrator Brooks-LaSure:
The Senior Care Pharmacy Coalition (SCPC) appreciates the opportunity to comment on the CMS Proposed Rule entitled “Medicare Program: Contract Year 2023 Policy and Technical Changes to the Medicare Advantage and Medicare Prescription Drug Benefits Programs;” Agency Docket Number CMS-4192-P (the Proposed Rule).1 SCPC is the only Washington-based organization exclusively representing the interests of long-term care (LTC) pharmacies. SCPC’s membership includes 80% of all independent LTC pharmacies. Our members serve one million residents daily in skilled nursing facilities and assisted living communities across the country.2 Given the distinct characteristics of the LTC patient population and the enhanced clinical responsibilities of LTC pharmacies, we offer unique perspectives on CMS’ initiatives and proposals, particularly how Medicare Prescription Drug Benefit (“Part D”) policies and requirements impact the pharmacy community.
SCPC’s comments focus on the CMS “pharmacy price concessions to drug prices at the point of sale” proposal, which would require all “Direct and Indirect Remuneration” (DIR) fees charged to pharmacies by Part D Plans (PDPs) or their Pharmacy Benefit Managers (PBMs) be passed through to beneficiaries at the point of sale. 87 Fed Reg. at 1845, 1909. We believe that CMS should eliminate DIR fees rather than require that PDPs/PBMs pass them on to beneficiaries at point of sale. Should CMS nonetheless proceed with the proposal, the agency should assure that implementation does not inadvertently damage pharmacies and should prevent PDPs/PBMs from shifting any economic losses they sustain to pharmacies. Our comments explain these conclusions.
Click here to read the full letter.
Recent Posts
-
Check out SCPC CEO Alan Rosenbloom on the Pharmacy Podcast Network’s “PBM Reform Podcast”
SCPC President and CEO Alan Rosenbloom speaks with the Pharmacy Podcast Network the importance of advocating for PBM reform, the status of the LTC Pharmacy Definition Act, LTC Pharmacy at-home, drug pricing legislation and its implications for LTC Pharmacy, and more.
-
SCPC Applauds House Oversight and Accountability Committee Chair James Comer for Launching Investigation into PBM Practices
The Senior Care Pharmacy Coalition (SCPC), the only Washington-based organization exclusively representing the interests of long-term care (LTC) pharmacies, applauds House Committee on Oversight and Accountability Chairman James Comer (R-KY) for launching an investigation into pharmacy benefit managers (PBMs) and their tactics that are harming patient care and increasing costs for many patients.
-
Senior Care Pharmacy Coalition Provides Comments on Improving Care for Dually Eligible Enrollees
The Senior Care Pharmacy Coalition (SCPC), the only Washington-based organization exclusively representing the interests of long-term care (LTC) pharmacies, has responded to a Request for Information issued by a bipartisan group of Senators led by Senator Bill Cassidy (R-LA) regarding policy recommendations to improve care for enrollees dually eligible for Medicare and Medicaid programs (dual eligibles) and substantially reduce the amount of money both programs otherwise would expect to spend over time.
Stay in the Know
Get the latest news and updates on issues impacting the long-term pharmacy community.