Hospital Pharmacy - December 2017 - 741

Gabay
aggregated effective rate or otherwise except in the case such
claim is found to not be a clean claim." Despite the Act's
introduction in both Houses of Congress, forward progress
has been slow and there is no specific timeline for when the
bill may be officially considered.
In summary, DIR fees were initially created by CMS with
the enactment of Medicare Part D to track rebates and other
price adjustments made to PBMs. More recently, PBMs have
expanded the use of these fees to "claw back" money from
pharmacies on already dispensed medications. Community
and specialty pharmacies claim these fees negatively impact
their finances, are not transparent, and hurt patients and
taxpayers while PBMs assert that these fees actually reduce
premiums for patients. Congress has stepped into the dispute
by introducing legislation that would halt retroactive DIR
fees. However, until movement on this legislation occurs,
pharmacies should perform due diligence when evaluating
PBM contracts and make sure that they understand all of the
potential fees to minimize disruption to their business.1
Declaration of Conflicting Interests
The author(s) declared no potential conflicts of interest with respect
to the research, authorship, and/or publication of this article.

Funding
The author(s) received no financial support for the research, authorship, and/or publication of this article.

References
1. National Community Pharmacists Association. Frequently
asked questions (FAQs) about pharmacy "DIR" fees. http://
www.ncpa.co/pdf/faq-direct-indirect-remuneration-fees.pdf.
Accessed October 7, 2017.

741
2. Frier Levitt LLC. PBM DIR fees costing Medicare and beneficiaries: investigative white paper on background, cost impact,
and legal issues. https://www.communityoncology.org/wpcontent/uploads/2017/01/COA_White_Paper_on_DIR-Final.
pdf. Published January 2017. Accessed October 7, 2017.
3. Drug Coverage (Part D). Medicare.gov: The official US government site for Medicare. https://www.medicare.gov/part-d/.
Accessed October 7, 2017.
4. Thielemier B. The dirt on DIR fees. http://www.pharmacytimes.
com/contributor/blair-thielemier-pharmd/2016/07/the-dirt-ondir-fees. Published July 25, 2016. Accessed October 7, 2017.
5. Anon. DIR fees: the clawback trend. http://therigy.com/dirfees-the-clawback-trend/. Published July 28, 2017. Accessed
October 7, 2017.
6. DIR fees. Drug Plan Fees Raise Costs and Threaten
Independent Pharmacies. National Community Pharmacists
Association website. http://www.ncpanet.org/advocacy/pbmresources/lack-of-transparency-and-higher-costs/dir-fees.
Accessed October 7, 2017.
7. Toich L. Direct, indirect remuneration fees harmful to many
except these managers. http://www.pharmacytimes.com/news/
direct-indirect-remuneration-fees-harmful-to-many-exceptthese-managers. Published February 2017. Accessed October
7, 2017.
8. Toich L. Legislation would halt retroactive DIR fees. https://
www.specialtypharmacytimes.com/news/legislation-wouldhalt-retroactive-dir-fees. Published February 2017. Accessed
October 7, 2017.
9. United States Congress. H.R. 1038 Improving Transparency
and Accuracy in Medicare Part D Spending Act. https://www.
congress.gov/bill/115th-congress/house-bill/1038. Accessed
October 7, 2017.
10. United States Congress. S. 413 Improving Transparency and
Accuracy in Medicare Part D Spending Act. https://www.congress.gov/bill/115th-congress/senate-bill/413. Accessed October
7, 2017.

https://www.communityoncology.org/wp-content/uploads/2017/01/COA_White_Paper_on_DIR-Final.pdf https://www.communityoncology.org/wp-content/uploads/2017/01/COA_White_Paper_on_DIR-Final.pdf https://www.communityoncology.org/wp-content/uploads/2017/01/COA_White_Paper_on_DIR-Final.pdf http://www.Medicare.gov https://www.medicare.gov/part-d/ http://www.pharmacytimes.com/contributor/blair-thielemier-pharmd/2016/07/the-dirt-on-dir-fees http://www.pharmacytimes.com/contributor/blair-thielemier-pharmd/2016/07/the-dirt-on-dir-fees http://www.pharmacytimes.com/contributor/blair-thielemier-pharmd/2016/07/the-dirt-on-dir-fees http://www.therigy.com/dir-fees-the-clawback-trend/ http://www.therigy.com/dir-fees-the-clawback-trend/ http://www.ncpanet.org/advocacy/pbm-resources/lack-of-transparency-and-higher-costs/dir-fees http://www.ncpanet.org/advocacy/pbm-resources/lack-of-transparency-and-higher-costs/dir-fees http://www.pharmacytimes.com/news/direct-indirect-remuneration-fees-harmful-to-many-except-these-managers http://www.pharmacytimes.com/news/direct-indirect-remuneration-fees-harmful-to-many-except-these-managers http://www.pharmacytimes.com/news/direct-indirect-remuneration-fees-harmful-to-many-except-these-managers https://www.specialtypharmacytimes.com/news/legislation-would-halt-retroactive-dir-fees https://www.specialtypharmacytimes.com/news/legislation-would-halt-retroactive-dir-fees https://www.specialtypharmacytimes.com/news/legislation-would-halt-retroactive-dir-fees https://www.congress.gov/bill/115th-congress/house-bill/1038 https://www.congress.gov/bill/115th-congress/house-bill/1038 http://www.ncpa.co/pdf/faq-direct-indirect-remuneration-fees.pdf https://www.congress.gov/bill/115th-congress/senate-bill/413 http://www.ncpa.co/pdf/faq-direct-indirect-remuneration-fees.pdf https://www.congress.gov/bill/115th-congress/senate-bill/413

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