As you all know by now, the Center for Medicare Services (CMS) has proposed a host of Medicare program changes that include modifications to Part D preferred pharmacy networks and to cost-sharing. Now we have the opportunity to speak up and tell CMS what we think of these changes — the opinions shared can help sway the final decision of CMS.
Between now and March 7th, CMS will accept comments on these proposed rule changes. Anyone can submit comments online (full instructions are below). Many pharmacists across the country have already submitted written comments, and we ask that you all do the same. Please also encourage others to submit comments before the March 7th deadline!
As a sample comment, modified from an NCPA template, here is Jason Wallace’s written comment. **Please note that Jason has edited this document to reflect his opinion which may differ from NCPA. This is just a sample letter and we ask that you include your own personal examples where appropriate, including your experiences with preferred pharmacy networks, patient choice and access, and the need for increased transparency in the industry.**
Instructions for Submitting Comments
Your comments should be submitted electronically via http://www.regulations.gov.
You will need to search for RIN: 0938-AR37 and then follow the “Comment Now” submission directions on the right side of your screen for “Medicare Program: Contract Year 2015 Policy and Technical Changes to the Medicare Advantage and the Medicare Prescription Drug Benefit Programs”.
The full proposed rule is online athttp://www.regulations.gov/#!documentDetail;D=CMS-2014-0007-0002.
The best way to submit a comment is to attach a document (Word or PDF) so as not to be limited in wordage by the text box.
The category you will be submitting under will be Health Care Professional/Association – Pharmacist.
Comments will be accepted until 11:59 p.m. ET on March 7, 2014.
Note: Do not include any patient-specific, HIPAA-protected information in your comments.
Useful Links to Track CMS Rule Changes
These links will help you track the CMS’ timeline for rule changes, full text and summaries of the proposed changes, and full text of all comments submitted to-date: