Reminder - CMS Proposed DIR Rule Comments Due January 16

Jan 12, 2018

As a reminder to all IPC stores, you have until the close of business Tuesday, January 16, 2018 to submit your comments to The Centers for Medicare & Medicaid Services (CMS) supporting its proposed rule that ends the retroactive DIR fees by requiring the PBMs to apply all pharmacy price concessions, including DIR fees, to the price of the drug at the point of sale.

The proposed rule will ensure that Part D Medicare enrollees have access to more affordable prescription drugs and more robust prescription drug coverage at the pharmacy they prefer. The rule also gives health plans a new tool to combat the opioid crisis.

Follow these steps to submit your comments to CMS:

  • Open this sample letter provided by IPC and enter your info into the open fields. The comments area provided is for listing examples of burden on patients and or pharmacy.
  • Save the completed letter
  • Visit the submission page at:, enter your information and upload your saved version of the letter
  • Hit continue at the bottom of the page
  • Review your submission, and check the box marked “I read and understand the statement above.” Note: the statement says, “You are filing a document into an official docket. Any personal information included in your comment and/or uploaded attachment(s) may be publicly viewable on the web.

These needed changes to how the PDP’s run the Part D plans are long overdue. IPC will be submitting formal comments on our support for these changes along with requests for other changes to further protect Part D patients and our members who serve them. But to ensure the DIR retroactive fees ends, CMS needs to hear YOUR voice in order to understand exactly how these DIR fees hurt patients in your community.

Do not stand back – submit your comments TODAY or anytime online up to the January 16, 2018 deadline.

For a fact sheet on the proposed rule, click here.

Questions or Concerns? Contact IPC’s Government Relations Team at: