NCPA Urges for Transparency, Consistency in Medicare Part D Reporting Requirements

The National Community Pharmacists Association (NCPA) is urging the Centers for Medicare & Medicaid Services (CMS) to require full transparency and consistency in Medicare Part D Reporting Requirements for community pharmacies. 

In comments submitted to CMS, NCPA called for the agency to collect information related to how pharmacy “performance” is measured in Medicare Part D to help address the problems independent pharmacies are facing in serving this patient population.  

Quality measurements in the Medicare Part D program are currently tied to pharmacy benefit manager (PBM) recoupments from the pharmacy post point-of-sale, rather than a standardized quality payment program. Over the past several years, community pharmacies have experienced an alarming increase in the amount of post point-of-sale price concessions extracted from their businesses.

“The increase in these retroactive fees continues to have a detrimental effect on Part D beneficiaries, the Medicare program, pharmacies, and taxpayers, and the trend is not slowing,” Ronna B. Hauser, PharmD, vice president of policy & government affairs at NCPA, wrote in the comments.

Direct and indirect remuneration fees (DIR) assessed against pharmacies participating in Medicare Part D plans have grown 45,000% from 2010 to 2017, according to NCPA. The lack of transparency and consistency in quality measurements creates several challenges for pharmacies in tracking performance. Moreover, community pharmacies sometimes do not have insight into their individual pharmacy’s quality standing in a given PBM network. 

“As pharmacies serve patients from multiple health plans and PBMs, there is an inconsistent and untenable application of the definition of ‘quality’ applied to pharmacies among the various payers,” Hauser said.

NCPA strongly urged CMS to require PBMs and plans to provide as much specifics as possible on the measures used in determining pharmacy DIR fees and identify potential issues across the variance of measures used by plans. 

NCPA is recommending CMS to collect certain information for each pharmacy performance metric being used by a plan/PBM. This includes: 

• The measure developer or entity responsible for development of the measure;
• How the measure was validated and tested;
• If the plan/PBM is using the measure in accordance with published measure specifications which have been validated and tested;
• If the plan/PBM is using the measure according to licensing agreements with measure stewards;
• Adjustments or modifications to measure steward specifications;
• Source of data used to calculate the measure;
• The minimum number of patients required in the denominator to reliably calculate the measure; and
• The platform, eg, EQuIPP, and measurement period used in calculating measure.

Read the full list of recommendations in the comments here.

Reference 

• Hauser R. Re: Information collection request on Medicare Part D Reporting Requirements (CMS-2021-0042-0001, CMS-10185). NCPA; May 18, 2021. Accessed May 26, 2021. https://ncpa.org/sites/default/files/2021-05/NCPA_Comment_CMS_PartD_Pharmacy_Performance_Reporting_05-18-21_FINAL.pdf