Big changes could be in store for 2019 Medicare drug plans – APhA submits compounding comments to FDA.

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Big changes could be in store for 2019 Medicare drug plans – APhA submits compounding comments to FDA. – (866) 348-2889

For the first time in 3 years, the CMS regulatory agenda released a Medicare Advantage and Part D proposed rule. The Part D proposed rule is a platform for presenting major policy changes for public comment.

One of the sections of the new proposed rule intends “to clarify that the any willing pharmacy requirement applies to all pharmacies, regardless of how they have organized one or more lines of pharmacy business.” Currently, some Medicare drug plans drive patients towards “preferred” pharmacies, or charge patients higher copays at pharmacies that aren’t “preferred” but may, for example, be more geographically convenient, provide services beyond traditional services, or where they have established relationships with pharmacists. Under the current framework, not all pharmacies may become a “preferred” pharmacy, even if willing to meet a plan’s requirements, because they may not satisfy the plan’s definition of a certain type of pharmacy. Pharmacy groups have long advocated for inclusion of “any willing pharmacy” provisions that allow patients to use any pharmacy that agrees to accept a plan’s conditions. The proposed rule clarifies that Part D plan sponsors may not exclude pharmacies with unique or innovative care delivery models from participating on the basis of not fitting the correct pharmacy type classification. Rather, under the proposed rule, CMS will consider “similarly situated” pharmacies include any pharmacy that has the capability of complying with standard terms and conditions for a pharmacy type.

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