Last week, the Centers for Medicare & Medicaid Services (CMS) released a new rule for Medicare Parts B and D. It proposes changes to protected classes, e-prescribing, and other issues. Links and background below.
Notably for the
Drug Channels audience, CMS also announced that it is considering—but not yet formally proposing—changes to how pharmacy price concessions are handled within Medicare Part D. These payments currently function like pharmacy rebates to Part D plans. They are therefore considered to be direct and indirect remuneration (DIR) and often called “DIR fees.”
Thanks to new CMS disclosures, we can now see why pharmacy owners hate these payments. Pharmacy DIR was $4 billion in 2017—about 1.5% of the retail pharmacy industry’s prescription revenues.
As I explain below, pharmacy DIR negatively affects the Medicare program and its beneficiaries in a manner similar to the impact of the rebates that manufacturers pay to plans. CMS wants the pharmacy DIR passed through to beneficiaries at the point of sale, i.e., when a prescription is dispensed.
Below, I explain this proposal, provide DCI's new analysis of DIR, and review the financial impact on drug channel participants. Keep in mind that the CMS proposal would *not* eliminate DIR fees or alter the financial impact of these payments on pharmacy profits. However, it’s clear that CMS wants plans and PBMs to change how these fees are computed and levied.
Pharmacy DIR is an important issue, because CMS is sharing some its views for a world without Part D rebates. The tough political question: Should taxpayers spend more to fix this problem?