Upcoming DIR Fee Changes and Their Potential Impact on 340B Programs

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The Centers for Medicare & Medicaid Services (CMS) has issued a final rule that goes into effect on January 1, 2024 that changes the way Direct and Indirect Remuneration (DIR) fees are collected. To understand the impact of this change, let’s review some background on DIR fees:

What are DIR Fees?

DIR fees are a type of fee imposed on pharmacies, particularly those that participate in Medicare Part D. DIR fees are a complex and often controversial aspect of the pharmacy reimbursement system. 

How do DIR Fees work?

DIR fees are essentially retroactive price adjustments that are made by pharmacy benefit managers (PBMs) or Medicare Part D plan sponsors to pharmacies after a prescription has been dispensed to a Medicare beneficiary. These adjustments in almost all cases will decrease the reimbursement paid to the pharmacy for a particular prescription.

What is the purpose of DIR

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