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NCPA Responds to Trump Administration RFI to Lower Rx Costs for Seniors

by NCPA | Jul 17, 2018

ALEXANDRIA, Va. (July 17, 2018)In a letter to U. S. Department of Health and Human Services Secretary Alex Azar, the National Community Pharmacists Association urged the Trump Administration to implement policies that would help lower costs for seniors and bring more transparency to the health care system – and a reprieve to locally owned community pharmacies.

The association submitted the comments in response to the administration's request for information related to its 'Blueprint to Lower Drug Prices and Reduce Out-of-Pocket Costs,' which the president announced May 11 in a Rose Garden event.

NCPA's letter urged that CMS consider eliminating pharmacy price concessions – known as DIR fees – altogether. At a minimum, NCPA asked that CMS require in its upcoming 2020 Part D rule that all pharmacy price concessions be included at point of sale. "A rule of this stature would demonstrate this administration's dedication to meaningfully address rising prescription drug costs for beneficiaries," the letter states.

NCPA urged CMS to develop a pharmacy-specific incentive-based performance program that recognizes the work of the pharmacy profession in service to the patient to reduce costs and improve medication adherence and health. The association also encouraged the administration to require that pharmacy benefit managers have a fiduciary duty to the entity for which they manage pharmaceutical benefits, a move that would shed light on opaque PBM practices, including the PBM's incentive to charge the plan more than the pharmacy is reimbursed and keep the difference as profit, which ultimately raises senior and taxpayer costs.

In addition to submitting its comments, NCPA:

  • Coordinated submission of a letter signed by more than 150 pharmacy stakeholders urging the administration to eliminate pharmacy direct and indirect remuneration fees in the Medicare Part D program, or at a minimum eliminate all retroactive fees.

  • Encouraged comment submission to HHS resulting in nearly 2,000 formal comments on the RFI from community pharmacists and other stakeholders, many of those urging the elimination of retroactive fees charged to pharmacies by PBMs. Those fees manipulate the price of the medication in such a way that Part D patients are pushed more quickly into Medicare's donut hole, where seniors must shoulder a substantial cost burden.

"We applaud the administration for its interest in reducing drug costs at the pharmacy counter; our recommendations provide a roadmap for getting there," said NCPA Chief Executive Officer B. Douglas Hoey, Pharmacist, MBA. "Pass along rebates to patients. Eliminate retroactive pharmacy DIR fees that bite pharmacies and patients alike. Create real performance-based incentives in Part D. Implement real transparency so that PBMs can't use their market power to profiteer on the backs of seniors, pharmacies, and taxpayers."

Hoey also noted that the association's input meshes well with the results of a Morning Consult survey conducted in late June, in which registered voters indicated strong support for cost-saving measures that would require insurers and PBMs to directly pass discounts they negotiate with drug companies to seniors; allow seniors to access lower copayments by assuring they can obtain prescriptions from the pharmacy of their choice; and prohibit PBMs from charging retroactive fees to pharmacies.


The National Community Pharmacists Association, founded in 1898, represents the nation's community pharmacists, including the owners of more than 24,000 pharmacies. The nation's independent pharmacies, independent pharmacy franchises, and independent chains dispense nearly half of the nation's retail prescription medicines.