New in 2016, CMS is now requiring pharmacy benefit managers (PBMs) to update maximum allowable cost (MAC) reimbursements to pharmacies at least every seven days. Unsurprisingly, OPA's phones have been ringing daily with pharmacies reporting that several PBMs are not acting in accordance with these new CMS standards.
When updating prices, Part D sponsors also must disclose the drug prices in advance of their use for reimbursement, and MAC prices must be disclosed to network pharmacies in a manner and format that is useable by the pharmacies, so that pharmacies can validate the prices. OPA, along with the National Community Pharmacists Association (NCPA) fought hard to have this regulation included in Part D for 2016, and we applaud NCPA for their work in keeping it intact.
These new compliance standards are now being put to the test, and ultimately, CMS can't act on information that they do not have. They want to hear from you. If you have a PBM that is not in compliance with the new regulations, it is important that you send examples to Antonio Ciaccia at email@example.com.
OPA is working closely with NCPA on this issue, and they have been addressing concerns on our behalf with CMS directly. If you are seeing disturbing trends, it is important to identify them, and that after you let us know, be sure to let your member of Congress know as well.