In May it was announced that CMS had issued a final rule that put an end to PBM’s retroactive DIR fees. The rule requires that the lowest effective negotiated price be reflected at the point-of-sale – so it does not eliminate DIR fees, it instead moves them to the point of sale.
The concern about early 2024 is slightly overstated. The only player that recoups DIR post hoc is the ♥️ company. Minimizing exposure to that company’s performance networks will mitigate the cash flow crunch to almost nothing, as the other companies take DIR at the time claims are paid.
The crunch in cash flow will be from March-April 2024, when DIR from the ♥️ Company for claims from Sep-Dec 2023 is recouped.
Yesterday I received a notorious contract amendment via certified mail. As you are familiar, the "amendment" is actually a new contract booklet with no indication as to what actually changed from the previous version. It is a 2-3 hour project for me to uncover what is changing and calculate how it impacts practice.
The amendment states vaccine administration will be reimbursed "up to $20." How does anyone sustain a business, any business, when they have no means of forecasting revenue?
Serious question, when did this become standard, widespread practice in pharmacy?
The concern about early 2024 is slightly overstated. The only player that recoups DIR post hoc is the ♥️ company. Minimizing exposure to that company’s performance networks will mitigate the cash flow crunch to almost nothing, as the other companies take DIR at the time claims are paid.
The crunch in cash flow will be from March-April 2024, when DIR from the ♥️ Company for claims from Sep-Dec 2023 is recouped.
Excellent article though!
Great points, Randy.
Yesterday I received a notorious contract amendment via certified mail. As you are familiar, the "amendment" is actually a new contract booklet with no indication as to what actually changed from the previous version. It is a 2-3 hour project for me to uncover what is changing and calculate how it impacts practice.
The amendment states vaccine administration will be reimbursed "up to $20." How does anyone sustain a business, any business, when they have no means of forecasting revenue?
Serious question, when did this become standard, widespread practice in pharmacy?