In comments to CMS on its proposed rule on Medicare Part D and Medicare Advantage, NCPA focused on proposed provisions expanding Medication Therapy Management in Part D.
While NCPA supports the intent of the expansion, it opposes further broadening coverage of MTM services without increasing payment to pharmacies, as doing otherwise will create an “unfunded mandate” on pharmacy.
Regarding CMS’ proposed revisions to Sstar Rratings in Medicare Part D and Medicare Advantage, NCPA opposes any hypothetical factors that CMS and Part D plans could take into consideration in star ratings that would have downstream effects on pharmacists’ scope of practice or patients’ clinical benefit.
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