Survey of Community Pharmacies Impact of Pharmacy Benefit Manager (PBM) Contracting and Auditing Practices on Patient Care

The Medicare Prescription Drug Program Integrity and Transparency Act (S. 867) was recently introduced by U.S. Senators Mark Pryor (D-Ark.) and Jerry Moran (R-Kan.) and would establish reasonable parameters around pharmacy audits and require regular updates to maximum allowable cost (MAC) lists and generic reimbursement in Part D.

While Part D pharmacy audits are necessary to detect fraud and abuse, PBMs are abusing this process by singling out expensive drugs and targeting typographical errors in order to recoup significant amounts of money that are in turn not turned over to the Medicare program. Also, pharmacies are typically forced to sign contracts with Part D plans and/or PBMs without any disclosure of the terms and conditions surrounding reimbursement for generic drugs. Increasingly, pharmacies are being paid below their costs to dispense and the Maximum Allowable Cost (MAC) lists are not updated on a regular basis in order to reflect generic drug spikes.

In order to provide lawmakers with the scope of the challenges faced by independent community pharmacies with regard to audits and MAC pricing in Part D, please respond to the following survey. Your responses will help to bolster NCPA advocacy efforts with regard to S. 867—a bill that would make fundamental changes with regard to audits and MAC pricing in Part D.