On September 24, 2026, the Centers for Medicare & Medicaid Services (CMS) published a request for information (RFI) seeking input on standards for reasonable and relevant pharmacy contract terms and conditions under Medicare Part D. The RFI is an initial step toward implementing Section 6223 of the Consolidated Appropriations Act, 2026, which requires Part D plan sponsors to permit pharmacies meeting a plan’s standard contract terms to participate in its network and establishes a January 1, 2029, effective date for the new contracting standards.
Scope of the RFI
CMS seeks feedback on a broad range of Part D pharmacy contracting practices, including reimbursement, network participation, contract transparency, pharmacy performance measures, auditing, and restrictions on dispensing. CMS also invites commenters to address differences among pharmacy types, geographic markets, and plan arrangements, as well as the effects of vertical integration among health plans, pharmacy benefit managers (PBMs), and pharmacies.
Of particular interest, the RFI invites comments on long-term care (LTC) pharmacies and how pharmacy type, contracting practices, and vertical integration may affect pharmacy access and competition. These issues may be particularly relevant to exclusive contracting arrangements between LTC facilities and pharmacies, which can affect Part D plan sponsors’ ability to use other network pharmacies to serve LTC residents.
Potential Implications
The RFI provides an opportunity for stakeholders to inform CMS’s development of standards that could materially affect Part D pharmacy contracting. CMS’s questions also signal that future action may extend beyond reimbursement terms to broader contracting practices and network access.
The agency intends to use the information received to inform future rulemaking. Comments must be submitted by November 23, 2026.
We will continue to monitor developments as CMS works towards implementing new contracting standards.
The RFI is available here (91 Fed. Reg. 60,568).
