Each NACDS member company has a powerful opportunity to submit official comments to the Centers for Medicare & Medicaid Services (CMS) in support of direct and indirect remuneration (DIR) fee reform concepts described in the agency’s proposed rule, “Modernizing Part D and Medicare Advantage to Lower Drug Prices and Reduce Out-of-Pocket Expenses.” The deadline to submit your company’s comments is January 25, 2019, at 5:00 p.m. EST.

When joining in this important movement, please keep in mind it is more effective for your company’s comments to reflect the authentic voice of the company, rather than to resemble a template. The main point to convey – with your company’s own voice – is that DIR fee reform is vital for helping to reduce patients’ out-of-pocket drug costs at the pharmacy counter, and for the viability of pharmacy patient care and the value that this care creates in the form of reductions in overall healthcare costs. Please urge CMS to take swift action on the DIR fee reform aspects of “file code CMS-4180-P” – and to assure that DIR fee reform is implemented for plan year 2020.

Other tips for submitting impactful comments include:

  • Reference file code CMS-4180-P at the top of your company’s comments;
  • Review the detailed submission instructions outlined on the first page of the proposed rule and ensure sufficient time for mailed submissions to arrive by January 25th; and
  • Share with NACDS an electronic copy of your company’s comments by emailing the document to todonnell@nacds.org.

In the development of your comments, please feel free to contact Tom O’Donnell, NACDS’ senior vice president of government affairs and public policy, at (703) 837-4216 or todonnell@nacds.org.

Thank you in advance for planning now to submit your company’s comments for arrival at CMS by the January 25, 2019, 5:00 p.m. EST deadline.