CMS publishes the Part D "reasonable and relevant" contract terms RFI

Plus: Merck restricts 340B covered entities to one contract pharmacy starting Oct 1. The day's rules, money, and enforcement, sourced and tiered below.

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Plus: Merck restricts 340B covered entities to one contract pharmacy starting Oct 1. The day's rules, money, and enforcement, sourced and tiered below.

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The Service Line Saturday, September 26, 2026
CMS publishes the Part D "reasonable and relevant" contract terms RFI
Plus: Merck restricts 340B covered entities to one contract pharmacy starting Oct 1. The day's rules, money, and enforcement, sourced and tiered below.
Record
The Medicare drug-plan middlemen fight just got its rulebook: CMS is asking the pharmacy industry to define what a "fair" contract between a pharmacy benefit manager and a pharmacy actually looks like.
CMS published the formal request for input September 24. Comments are due November 23. Whatever standards result will bind Part D pharmacy network contracts starting the 2028 plan year, effective January 1, 2029.
Record
A drugmaker just showed hospitals how little a winning lawsuit protects them: Merck is cutting most 340B hospitals down to one contract pharmacy each, even in states where courts have upheld pharmacy-access laws.
Merck's September 23 notice takes effect October 1. A hospital without its own outpatient pharmacy gets one designated contract pharmacy, and a wholly owned one only qualifies within 40 miles of the hospital.
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