“We’ve Got to Get This Right From the Start”: Expert Discusses MDPNP Impacts on Pharmacies

In an interview with Pharmacy Times, Ronna Hauser, PharmD, senior vice president of policy and pharmacy affairs at the National Community Pharmacists Association (NCPA), discussed concerns the association has with the implementation of the Medicare Drug Price Negotiation Plan (MDPNP). In addition to financial impacts on pharmacies, the MDPNP could also impact the pharmacist-patient relationship in terms of medication counseling and adherence monitoring for patients on the negotiated drugs.

Pharmacy Times: The NCPA is urging a freeze on the MDPNP’s implementation until robust safeguardsare in place. What specific safeguards do you believe are necessary to protect pharmacies’ financial viability and ensure continued patient access to medications?

Ronna Hauser, PharmD: I will say, when we say we'd like to see a freeze on the program, you know, we want to work in collaboration with CMS [the Centers for Medicare and Medicaid Services] to make this work for our patients. So, we're coming to the table to offer suggestions, solutions, recommendations, to make this work in the spirit of collaboration. So, when we say freeze, we mean just take a look at how the program has been implemented to date and change course. You know, please take some of our suggestions and recommendations and put them into effect, because if you don't, again, the economics of this program don't work. Our members cannot afford to participate in it; therefore, you're leaving a lot of gaps in patient care that no one wants to see.

Pharmacy Times: Beyond the financial aspects, how do you see the MDPNP affecting the pharmacist-patient relationship, particularly in terms of medication counseling and adherence monitoring for patients on the negotiated drugs?

Hauser: Right. Again, these are very commonly dispensed drugs, brand name drugs covered by Part D, that are dispensed very frequently in independent pharmacies and long-term care pharmacies. So, the program has to work, right? We can't afford to leave our patients at a spot where they might not be able to access their drugs at our pharmacies. That's not the outcome anyone wants. The outcome we need is, again, to make pharmacies whole within 14 days so that we can afford to dispense these drugs, and we have 10 drugs starting January 1, 2026, all commonly dispensed in community and long-term care pharmacies. We're adding 15 on in 2027, so everything's cumulative over the years. So, we've got to get this program right from the start, or patient access is going to be a huge concern.

Pharmacy Times: Is there anything you’d like to add?

Hauser: I just think it's important, from a big picture, to look at this in the most simple way possible. You have 10 drugs that go into effect in the drug price negotiation program from January 1, 2026. Again, [these drugs are] very commonly dispensed by independent pharmacies in the community and long-term care settings. You have maximum fair prices that are publicly available, new benchmarks for these drugs out there. We're going to be purchasing these drugs, as we do today, from our wholesalers, so we'll have expensive inventory on our shelves. We'll get paid when we dispense the drug to a Part D patient. We'll get paid no more than the maximum fair price by the pharmacy benefit managers, so we'll be getting undercut up front and getting a low payment from the PBMs up front—again, waiting to be made whole with manufacturer refunds. So, only approximately 40% of our cost to provide this product will be given to us up front by the PBMs. And again, there's no guarantee the PBMs will pay dispensing fees for these drugs. So, we're kind of operating at a loss. You know, off the bat, we're being paid low from the PBMs, and then we're being paid slow from the manufacturers. And everything that we've seen to date, again, in how this program is going to work and how CMS has stood it up, is everything is very voluntary for the manufacturers. Right? The manufacturers are recommended to pay us refunds based on WAC, or wholesale acquisition costs, minus MFP, or maximum fair price. If they would be mandated to do that, we think it would be a much better outcome and more stability for our members, but they are not mandated to pay us that standard default refund amount, so they could pay us a refund based on a different amount.

And also, the manufacturers are not mandated to use the payment module to pay us our refund payments. They could use another vendor and another module, so…because we're talking about 10 drugs, you could have 10 different portals, you know, coming into an independent pharmacy to pay us our refund amount from 10 different manufacturers. That's a reconciliation nightmare for pharmacies. So, you know, we're like, “Do this in a more standardized manner. Tell the tell the PBMs they have to pay us MFP plus a professional dispensing fee. Then tell the manufacturers they have to pay us the standard default refund amount, which is WAC minus MFP. Then make sure those manufacturer refund payments are received by the pharmacies in 14 days.” You know, if all of these pieces would fall into place, we feel like we'd have much better assurances that we could participate in this program. But because none of that is assured to date, and we have a lot of voluntary steps along the way, and unknown steps along the way, again, we don't see those manufacturer plans till September. It just makes it extremely difficult for a pharmacy to make a decision on whether they can participate in this program or not.

And by the way, you know, there's an outstanding rule that's not final yet, where CMS is telling us we have to participate, because they're going to force the PBMs to tell us we have to participate. So, if you want to be in, you know, PBM X’s Part D network, you have to participate in this program. So, therefore, you are in a really, really negative situation at that point in time. And many PBMs tie their Part D network agreements to non-Part D lines of business, so if you can't afford to participate in the Medicare direct price negotiation program, then you're not participating in the Part D program for that PBM. Oh, then, by the way, you may not be participating in programs for their other lines, non-party lines of business. So, it's just a very bad domino effect, you know, each step of the way. So, we've used our analysis to, you know, educate folks within the administration on the economic impact to our members and we’re really hopeful that some changes will be made soon.