The recent National Community Pharmacists Association (NCPA) Annual Convention in Kansas City brought together pharmacy owners, industry leaders, and advocates from across the country to discuss the challenges and opportunities facing independent pharmacy. While topics ranged from operations and patient care to business growth, one issue rose above all others: CMS’s Request for Information (RFI) on Medicare Part D “reasonable and relevant” pharmacy contracting standards.
NCPA leaders repeatedly emphasized that this may be the most important opportunity independent pharmacies have had in years to influence federal pharmacy policy. Earlier this year, Congress directed the Centers for Medicare & Medicaid Services (CMS) to develop and enforce standards requiring Medicare Part D contracts to contain terms that are “reasonable and relevant.” CMS has now begun that process by asking pharmacies, PBMs, and other stakeholders for direct input through a formal Request for Information.
What makes this so significant is that CMS is not simply asking about reimbursement rates. The agency is seeking feedback on many of the issues independent pharmacies have struggled with for years, including contract transparency, reimbursement methodologies, audits, performance measurements, preferred networks, pharmacy access, and other contract provisions that impact a pharmacy’s ability to serve Medicare beneficiaries.
Throughout the convention, NCPA leaders stressed that this is independent pharmacy’s chance to put every concern on the table. The comments that CMS receive will help shape future regulations governing Medicare Part D contracts and PBM oversight. Many speakers described it as a “once-in-a-generation” opportunity to create meaningful reforms that improve fairness, transparency, and accountability in Part D contracting.
However, there was also a clear warning: comments matter only if pharmacies participate. CMS is looking for real-world examples supported by facts and experiences. Independent pharmacies are uniquely positioned to explain how current contracting practices affect patient access, pharmacy sustainability, and care delivery in their communities. NCPA encouraged pharmacies to submit thoughtful, individualized comments that include examples of reimbursement challenges, audit concerns, network participation barriers, and other contract-related issues they encounter.
IPC is actively engaged in this process and will be submitting formal comments to CMS. Our Government Relations team is gathering information, examples, and data to help ensure the voices of independent pharmacies are represented during this critical rulemaking effort. IPC also plans to provide members with resources, guidance, and tools to help develop their own submissions. In the meantime if you would like to participate, please feel free to submit comments under the NCPA Legislative Action Center. There is no limit to the number of comments you can submit, we simply ask that you customize each comment and back up your comments with data from your personal experience.
Submit your comments:
ncpa.org/legislative-action-center
The deadline for comments is November 23, 2026.
If you want to see changes to Medicare Part D, now is the time to speak up. The reforms Congress enacted earlier this year created the opportunity. What happens next depends on whether independent pharmacies help CMS understand what reasonable and relevant contract terms should actually look like. Simply put, if you want a seat at the table when the future of Medicare Part D is being written, submitting comments is one of the most important actions you can take.
IPC will continue to keep members informed as this process moves forward and will provide additional resources to support participation in the weeks ahead. Together, we can help ensure that future Medicare Part D policies strengthen patient access, preserve pharmacy choice, and create a fairer environment for independent community pharmacies.
