Patient Disruption - Patients may be denied medication they have obtained under Part D for years. The coalition recommends a standard CMS fact sheet or similar document, available online, to help pharmacists answer beneficiaries ™ questions. Supply Chain Concerns “ Denying access to one generic drug will likely increase demand for equivalent generics, of which sufficient supply may not be readily available. Such supply chain issues further endanger beneficiary access. Inconsistent Implementation by Part D Plans - Some Part D plans may employ point-of-sale (POS) edits at the pharmacy level to block dispensing of unlisted drugs, but others may not, frustrating patients and pharmacists alike. To promote consistency in implementation, the coalition recommends that CMS either update the CMS non-matched NDC list on a more frequent basis or require plans to utilize the FDA ™s NDC list to keep POS edits current. Retroactive Reversal of Claims “ The coalition urges CMS to prohibit retroactive reversal of approved claims for NDCs that appear on the non-matched list. These claim reversals would be unfair to pharmacies that dispensed the medications pursuant to plans ™ approval of claims at the point of sale.

The groups have also urged brand and generic drug manufacturers to step up their efforts to ensure their products ™ NDCs are registered with the FDA, as evidenced by a Nov. 17 letter from NCPA to their trade associations. 

Source: American Pharmacists Association