Dear APCI members,
As you most likely already know, the Center for Medicare and Medicaid Services (CMS) recently released a proposed rule to address direct and indirect remuneration (DIR) fees in Medicare Part D. APCI is currently analyzing the proposed rule and its potential effects on our membership. One thing is clear: While the proposed regulation would save Part D beneficiaries money at the counter, this proposal falls far short of fixing the many problems in Part D and continues to empower plans and PBMs to engage in problematic practices, including:
- Overcharging beneficiaries, including depriving them of “pharmacy price concessions” in the coverage gap and of rebates through all coverage phases
- Continuing to impose retroactive fees against pharmacies
- Obscuring drug costs by tying ingredient drug costs to poorly defined outcomes, scores, and metrics
- Continuing to steer patients to PBM-affiliated pharmacies
- And continuing to allow PBMs to operate largely unchecked
APCI believes the time is now to put forth comprehensive solutions to resolve the problems in Part D – including advocating for a transparent prescription drug system. This will take engaging not only with CMS but also with Congress in an effort rein in plans and PBMs who have failed patients and exploited the public trust.
CMS is requesting public comments on the proposed rule; APCI will be submitting written comments and will be engaging with CMS throughout their rule making process. APCI will also be providing talking points for members who wish to submit comments of their own. APCI’s talking points will empower our members to engage with CMS and Congress for real, meaningful reform.
If you are interested in submitting comments of your own – and we strongly encourage you to do so – we're asking that you hold off until APCI releases its talking points; these points will help our members effectively engage with CMS and Congress on this critically important issue.
In the meantime, please know that APCI is working hard on your behalf to fix a broken Part D system. Stay tuned for more information and be on the lookout for an advocacy call to action when our comment talking points are finalized soon.