New Medicare Part D Requirements: Engaging Pharmacies in Regulatory Changes

On September 24, 2026, the Centers for Medicare and Medicaid Services (CMS) entered a crucial phase of implementing new Medicare Part D requirements, seeking stakeholder feedback on establishing equitable standards for pharmacy participation in Part D networks.

The Request for Information (RFI) issued by CMS, which closes on November 23, 2026, represents an important opportunity for pharmacies. This consultation is not just procedural; it provides a platform for pharmacies to communicate their operational challenges with Medicare Part D plans. These could have significant repercussions on reimbursement strategies, network accessibility, contract obligations, and audit procedures. CMS's focus includes examining payment policies, network participation terms, specialty pharmacy classifications, and audit standards, all of which are pivotal to pharmacy operations under Part D.

Implications for Pharmacies

The evolving CMS regulations pose both challenges and opportunities for pharmacies, particularly concerning reimbursement and participation in Medicare Part D networks. Independent pharmacies, in particular, have much at stake—they are encouraged to evaluate the RFI carefully and provide detailed feedback on real-world implications of these policies. By contributing their insights, these stakeholders can influence the shaping of policies that could substantially impact their business operations.

Support for Pharmacies

To assist pharmacies in navigating this consultation process, the Duane Morris Pharmacy Litigation Group offers guidance on effectively engaging with CMS. Pharmacies are urged to prepare their responses and seek advice to ensure their voices are heard in this pivotal regulatory discussion.