For years, independent pharmacies have dealt with Medicare Part D contracts containing reimbursement rates, network restrictions, audit requirements and other terms they have little ability to negotiate.
Now, you have an opportunity to tell the federal government what needs to change. The Centers for Medicare & Medicaid Services (CMS) is asking pharmacies and other stakeholders to provide input as it develops federal standards defining what constitutes “reasonable and relevant” pharmacy contract terms and conditions under Medicare Part D. Congress directed CMS to establish these standards as part of the Consolidated Appropriations Act, 2026 (Otherwise known as the Big Beautiful Bill). The standards must be established by April 2028 and will apply beginning with the 2029 Medicare Part D plan year.
The deadline to submit comments is November 23, 2026.
IPC will be submitting comments on behalf of our members and independent community pharmacy. But IPC’s comments cannot replace yours.
CMS needs to hear directly from you the pharmacy owners about what is happening behind your counters and in your contracts.
Why Your Comments Matter
This isn’t simply another request for general feedback.
CMS is specifically asking about many of the contracting practices that can directly affect an independent pharmacy’s ability to participate in Medicare Part D and serve its patients. The questions cover reimbursement and dispensing fees, MAC pricing, GER and BER arrangements, network participation, preferred and specialty networks, contract transparency, audits, performance measures, dispute processes, contract changes and the leverage pharmacies have when negotiating with plans and PBMs.
In other words, CMS is asking questions you as an independent pharmacy owner are uniquely qualified to answer.
IPC’s Government Relations team has emphasized internally that pharmacy comments should go beyond reimbursement alone and address the broader contract terms and conditions that create challenges for independent pharmacies.
This is your ONE chance to explain those challenges directly to the agency responsible for developing the standards.
Don’t Just Tell CMS There Is a Problem. Show Them.
The most valuable comment you can provide is one grounded in your pharmacy’s actual experience.
CMS is explicitly encouraging commenters to provide as much detail as possible, including quantitative data, empirical analysis, de-identified contract language and information showing differences by pharmacy type, geography, drug category or other relevant circumstances. CMS is also seeking evidence about how these issues affect Medicare beneficiary access and outcomes.
Think about the experiences you have had with Part D contracts:
- Have reimbursement rates failed to cover your acquisition costs?
- Have contract terms or reimbursement methodologies made it difficult to know what you will ultimately be paid?
- Have you faced barriers to participating in preferred or specialty networks?
- Have contract changes, audit practices or dispute processes created unnecessary burdens?
- Have these practices affected which medications you can afford to stock or your ability to serve Medicare patients?
IPC Government Relations materials recommend identifying a specific contracting challenge, explaining how it affects your pharmacy or patient access, and recommending the change you believe CMS should make.
Be specific. Use numbers where you can. Provide real examples. Explain the impact on your pharmacy and your patients.
And because CMS states that public comments are posted publicly, do not include patient-identifying information or confidential business information that should not become part of the public record.
Act Before November 23
Every member and affiliate needs to participate through either the IPC VoterVoice campaign or another submission source and submit an individualized comment.
Don’t assume someone else’s comment will tell your story. Don’t assume IPC’s submission alone is enough.
If there are Part D contracting practices you believe must change, now is the time to put them on the record.
CMS must receive comments by November 23, 2026. You can also review the complete Federal Register Request for Information, including every issue on which CMS is requesting feedback.
