Information For DPL XXXVI
The American Society for Pharmacy Law (ASPL) is an organization of attorneys, pharmacists, pharmacist-attorneys and students of pharmacy or law who are interested in the law as it applies to pharmacy, pharmacists, wholesalers, manufacturers, state and federal government and other interested parties.

ASPL is a non-profit which encourages diversity & inclusion with the Society, regardless of differing backgrounds, perspectives, experiences, orientations, origins, and practice settings. The Society embraces participation and diversity as it leads to advancing our purpose: 

  • Furthering knowledge in the law related to pharmacists, pharmacies, the provision of pharmaceutical care, the manufacturing and distribution of drugs, and other food, drug, and medical device policy issues;
  • Communicating accurate legal educational information; and
  • Providing educational opportunities for pharmacists, attorneys, and others who are interested in pharmacy law

Latest News

September 2, 2025

CMS Provides Guidance Memo on Pharmacy Reimbursement in MDPNP

CMS issued a memo on the Medicare Drug Price Negotiation Program (MDPNP), highlighting guidance on fair reimbursement, dispensing fees, network adequacy and LTC pharmacy. Some key highlights:

Fair reimbursement: CMS stated that it continues to hear concerns that pharmacies fear reimbursement from the Part D plan plus the manufacturer refund might be below the price the pharmacy paid to acquire the selected drug, including potentially below the maximum fair price (MFP) for the selected drug. CMS will closely monitor whether further programmatic adjustments are needed.

Dispensing fees: CMS stated that it expected Part D plan sponsors' dispensing fees to sufficiently compensate network pharmacies so that enrollees can be assured network access to selected drugs. CMS stated that examples of pharmacy costs that can be included within the dispensing fee are salaries, time associated with checking for coverage, filling the container, packaging, and overhead (including IT).

Network adequacy: CMS reminded all Part D plan sponsors of the network adequacy requirements for contracted pharmacies.

LTC pharmacy: CMS stated that all of a Part D sponsor’s plan enrollees who reside in a long-term care facility must be able to routinely receive their Part D benefits through the plan’s network of LTC pharmacies in order for a Part D plan sponsor to be in compliance with CMS’s LTC convenient access standard. 

[Network Adequacy Requirements and Dispensing Fees for Selected Drugs. CMS 25 Aug 2025.]