In comments to the agency, NACDS calls for reforms that work within real-world pharmacy workflows — reducing the administrative burdens that delay patients' access to their[...]

The National Association of Chain Drug Stores (NACDS) submitted comments to the Centers for Medicare & Medicaid Services (CMS) on a proposed rule on prior authorization for prescription drugs and interoperability (CMS-0062-P), urging the agency to ensure the proposals work within real-world pharmacy workflows and reduce the administrative burdens that delay patient access to medications.

NACDS supports CMS' goal of expanding electronic prior authorization, advancing data exchange, and reducing administrative burden. However, the Association cautioned that the proposal remains oriented around payers and prescribers without fully accounting for pharmacies - the very setting where coverage and prior authorization barriers are most acutely encountered.

"NACDS appreciates CMS' leadership in advancing interoperability and prior authorization reform, and we support the rule's overall direction," said NACDS President and CEO Steven C. Anderson, FASAE, CAE, IOM. "But to deliver meaningful improvement for patients, the final rule must do more than expand data exchange requirements - it must ensure those requirements work in real-world workflows, particularly in pharmacy settings where coverage requirements and patient care needs converge."

In its comments, NACDS recommended that CMS:

• Integrate pharmacies into the data ecosystem, ensuring new interoperability tools are usable within pharmacy systems and recognize pharmacists in their dual role - both as dispensers and as providers of clinical services.
• Make prior authorization actionable, requiring real-time information with clear next steps so pharmacists are not left making phone calls, resubmitting requests, and chasing down prescribers and payers to move a prescription forward.
• Make denial reasons useful, requiring them to be standardized and actionable so pharmacists can immediately determine how to proceed rather than initiating another round of manual follow-up.
• Reflect pharmacy's real-world starting point, recognizing that pharmacies were largely excluded from the federal incentives that advanced health IT in other care settings, and providing for flexible, phased implementation and realistic timelines that match where pharmacy systems stand.
• Protect continuity of care, requiring reliable, redundant systems and fallback processes so pharmacies can keep serving patients when other systems go down.
• Strengthen care coordination, including pharmacies in electronic event notifications around hospital admissions and discharges, and making patients' prior treatment history portable so they are not forced to repeat therapies that have already failed them when they change plans.

"Pharmacists are frequently the first to identify a coverage barrier and the closest point of contact for the patient who needs their medication," Anderson said. "When information is not actionable, that burden falls on pharmacy teams - and on patients. Reform should reduce that burden and improve access, not simply shift it downstream."