The Center for Medicare and Medicaid Services (CMS) continues to stand by a policy of imposing duplicate charges to pharmacies that offer different types of services under Medicare Part B, in clear contrast to Congressional intent under the Affordable Care Act (ACA).
Under CMS’ misguided interpretation, pharmacies that enroll or revalidate through both the 855S and 855B forms are charged duplicate fees for each form. This is particularly unfortunate for independent community pharmacies which are already burdened in Medicare Part B through excessive accreditation fees, low reimbursements and aggressive audits.
NCPA is encouraging CMS to reconsider its fee guidelines in accordance with Congressional intent in the ACA. Congress instructed the Secretary of HHS to charge a fee to each institutional provider of services. The legislation does not say that each institutional provider who provides two different services, such as vaccinations or durable medical equipment (DME) shall pay the fee for each item or service. Had Congress intended for the fee to be applied for each individual service, lawmakers would have specified this.
Currently, pharmacies are being charged twice for the same fraud, waste and abuse screening that is conducted for each form. NCPA’s recent letter to CMS also notes that it makes little sense that CMS waives one set of fees for these screenings for pharmacies that serve both Medicare and Medicaid, but not for pharmacies that file separate 855 forms to serve patients solely in the Medicare system.
CMS ought to reconsider this decision to align its policies more closely with Congressional intent and only charge pharmacies one revalidation fee.