July 27, 2018

National Association of Specialty Pharmacy Comments on the HHS Drug Pricing Blueprint

From: Husch Blackwell



Direct and Indirect Remuneration

In NASP’s view, pharmacy benefit managers (PBMs) must better align their incentives with the ultimate payer – the consumer.  The association emphasizes its support for previous CMS proposals that address pharmacy price concessions, otherwise known as DIR (direct and indirect remuneration) and post-adjudication fees. The collection of these fees, which may be assessed months after claims are submitted and reimbursed, can provide an incentive by a PBM or plan sponsor for higher drug list prices and higher rebates according to NASP.  As a result, this practice creates uncertainty for specialty pharmacies and can threaten the pharmacies’ ability to provide high-touch services that are essential for optimal clinical outcomes for patients with complex health conditions.

NASP believes this model can drive higher prices and shift more drug costs onto the shoulders of Medicare beneficiaries, the Medicare trust fund, and, ultimately, to taxpayers. NASP recommends reform that would ensure that DIR and administrative fees be based on quality or performance measures specific to specialty pharmacies; metrics that are determined by the “broad stakeholder community.”  Consumers and taxpayers will continue to overpay for life-saving drugs, NASP says, until measures are appropriately applied to specialty drugs and services and such fees should be suspended for the time being.

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