PCMA Statement on CMS Letter to Pharmacy Benefit Companies

(Washington, D.C.) — The Pharmaceutical Care Management Association (PCMA) issued the following statement in response to a letter issued by the Centers for Medicare and Medicaid Services (CMS):

“The Pharmaceutical Care Management Association, PCMA, representing America’s pharmacy benefit companies, believes it is important to respond to a recent letter issued by the Centers for Medicare and Medicaid to pharmacy benefit companies, as well as health plan groups. At the outset, we want to point out that the PBM industry is highly competitive, with 73 full-service PBMs competing for business from the employers, unions, and health plans that voluntarily hire them.

“Like CMS, our companies are also concerned about the sustainability of pharmacies nationwide. Pharmacy benefit companies recognize the vital role pharmacies of all sizes and in all geographic locations – and especially independent and community pharmacies in rural areas or “pharmacy deserts” – play in creating access to prescription drugs for patients.

“A strong partnership between PBMs and pharmacies means a better experience and more affordability for patients, which is our top priority. That’s why PBMs are taking real action to support community pharmacies in rural areas through new programs that increase reimbursements and allow rural pharmacists to spend more time with patients. And that’s why PCMA has supported and advocated for new authorities for pharmacists to practice at the top of their license so that they can provide, and be reimbursed for, more services that benefit patients. This includes vaccinations, which through the COVID-19 pandemic demonstrated the vital role these clinicians can play in addressing public health emergencies. PCMA continues to work with CMS on streamlining policies on vaccine administration to ensure that process works seamlessly for pharmacists and patients.

“Specific to the CMS’ consideration of pharmacy access and prompt payment standards, we are confident that pharmacy benefit companies have complied and continue to comply with Medicare prompt pay requirements and pharmacy network adequacy standards. In fact, CMS confirmed that all Medicare Part D plans met the retail pharmacy network adequacy standards for 2024. Our companies’ compliance is critical to convey and was absent from the letter so we feel compelled to proactively share this information.

“In the letter, CMS also raised the Medicare Part D rule on pharmacy direct and indirect remuneration (DIR) taking effect on January 1. Again, we share concerns about the rule and raised concerns about the consequences of the rule for pharmacies. In fact, PBMs have opposed the Part D pharmacy DIR regulation in every form it has taken since 2014, and we still oppose it.

“We look forward to continuing to partner with CMS and pharmacies to maintain a healthy pharmacy market as a means of advancing access to prescription drugs in the United States, especially in rural areas.”

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