Comment on CMS-2026-2212-0001
National Association of Specialty PharmacySupportTrade association
Summary: The National Association of Specialty Pharmacy (NASP) supports the implementation of Section 6224 but urges CMS to establish a clear, accreditation-based definition of "specialty pharmacy" and an ownership-based definition of "affiliate." They argue that CMS must ensure rules do not unfairly impact independent pharmacies and should require PBMs to disclose all pharmacy price concessions at the point of sale rather than through post-adjudication fees.
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