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In comments to CMS, the Senior Care Pharmacy Coalition (SCPC) said PBMs' pharmacy fees should be completely eliminated, rather than redirected or reformed as proposed by CMS. SCPC asserted that "pharmacy incentive payments" have "grown faster than any other category of DIR received by sponsors and PBMs," and that because the amounts exceed "bid" calculations, they do not help beneficiaries or the program, but instead are being misused by PBMs to contribute to plan profits. SCPC also that CMS' "conceptual 'point of sale' (POS) policy solution unfortunately would not be effective for LTC pharmacy and the beneficiaries they serve. As the agency knows, a very large percentage of LTC residents are 'dual eligible' for both Medicare and Medicaid. Duals do not pay for their medications at all. They do not pay Part D premiums, copays or deductibles and are exempt from the 'donut hole' and other coverage levels of the Part D program. For these beneficiaries, 'passing through' pharmacy fee DIR at the POS makes no sense since it is not possible for their out-of-pocket costs to be lower than $0.00."
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