Alan Arville, Member of the Firm, and Kala Shankle, Associate, co-present a roundtable discussion, “An Overview of Changes to Claw Backs in CMS’ Part D Final Rule,” hosted by the American Society for Pharmacy Law.
For years the Centers for Medicare and Medicaid Services (CMS) has been considering ways to reform the use of pharmacy Direct and Indirect Remuneration (aka pharmacy DIR) in the Medicare Part D program. This spring CMS took highly anticipated action on DIR reform with its finalization of Medicare Advantage and Part D Final Rule for Contract Year 2024, which requires Part D plans to include certain kinds of pharmacy DIR (colloquially known as “claw backs”) in a pharmacy’s negotiated price at the point of sale. According to CMS, the rule is a win for patients who will see lower out-of-pocket costs at the pharmacy to the tune of $26.5 billion between 2024 and 2032. Some pharmacy advocates also claim the final rule is an important step to bring transparency to pharmacy negotiated prices. Alan and Kala give a historical overview of CMS’ actions on pharmacy DIR over the past 10 years. They then analyze CMS’ final rule and apply the analysis through the lens of pharmacies, payers/PBMs, and pharmaceutical manufacturers.
- Review CMS actions on pharmacy DIR over the past ten years
- Analyze pharmacy DIR changes in CMS’ Medicare Advantage and Part D Final Rule for Contract Year 2024
- Understand how this change may impact pharmacies, payers/PBMs, and pharmaceutical manufacturers
For more information and to register, please visit ASPL.org.