DIR January 1, 2024 Awareness
On April 29, 2022, the Centers for Medicare & Medicaid Services (CMS) issued changes to the Medicare Part D final rule for 2023, but one of those changes doesn’t take effect until January 1, 2024. This is the piece around direct and indirect remuneration (DIR) fees. The short summary of this upcoming change is that DIR fees will be applied at the point-of-sale as of January 1, 2024, which means that the real-time reimbursement a pharmacy sees is your actual, final reimbursement rate on the Medicare Part D claim.
The Good:
You will no longer have to deal with retro-active DIR fees after January 1, 2024.
You will know exactly what you are being reimbursed on the claim at the point-of-sale.
The Bad:
Your point-of-sale reimbursement rate will be lower. As a result, in early 2024, many pharmacies will experience a crunch in your cash flow as your point-of-sale reimbursement drops and you are still paying retroactive DIRs fees.
The time to start planning for this change is NOW!
Look for resources available to help you plan for this change in cash flow. Good sources of help are the National Community Pharmacists Association (NCPA) and your PSAO. Please check back for additional information about resources we are aware of at Currus to help you plan and prepare.