On behalf of our member companies, the National Association of Chain Drug Stores (NACDS) writes to request a meeting to discuss the importance of fair and accurate reimbursement for community pharmacies for specialty drugs. As we previously noted, addressing both the cost of the drug product and the cost of dispensing is critical to maintaining patient access to Medicaid pharmacy services, especially when considering the increasing cost of providing specialty drugs and services to the Medicaid population. We are requesting this meeting to speak to you to discuss possible options for CMS to provide further direction and/or guidance to the states in this policy area. We believe that if adequate direction and/or guidance is not provided, states will adopt insufficient reimbursement rates and dispensing fees for specialty drugs resulting in below-cost reimbursement for participation pharmacies.
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However, there are still concerns regarding proper reimbursement for providing specialty products and services. Although the Final Rule addresses cost-based reimbursement for traditional products, states are given flexibility to determine reimbursement for the cost of providing specialty products and services. Thus, this flexibility may lead to inadequate reimbursement to community pharmacy due to the rising costs associated with specialty
However, there are still concerns regarding proper reimbursement for providing specialty products and services. Although the Final Rule addresses cost-based reimbursement for traditional products, states are given flexibility to determine reimbursement for the cost of providing specialty products and services. Thus, this flexibility may lead to inadequate reimbursement to community pharmacy due to the rising costs associated with specialty