10/28/2026
📢 ARKANSAS PHARMACISTS: SUBMIT COMMENTS TO CMS BY NOVEMBER 19!
CMS is accepting comments through November 19, 2026, on its draft process for identifying “essential retail pharmacies” under the new Medicare PBM reform law passed in February 2026.
This is the second major CMS request for comments related to the new law this November. Pharmacy owners, operators, and pharmacists are encouraged to respond to both this request and the separate “Reasonable and Relevant” Medicare Part D contracting request.
Why does this matter?
Under the law, eligible pharmacies must be unaffiliated with a Part D sponsor or PBM and have no other retail pharmacy within:
📍 10 miles in rural areas
📍 2 miles in suburban areas
📍 1 mile in urban areas
These distances are established by law, but CMS needs input on how those distances are measured. The methodology could affect pharmacy designations and patient access to care.
RECOMMENDED POINTS TO ADDRESS:
🔹 Driving distance matters. Arkansas's mountains, forests, rivers, bridges, and winding roads can make pharmacies appear closer on a map than they actually are by road.
🔹 Use accurate locations and realistic routes. Measurements should reflect actual public road access, not ZIP code centers or routes patients cannot use.
🔹 Promote transparency. CMS should explain its geographic classifications, mapping sources, and calculations.
🔹 Allow corrections and appeals. Pharmacies need a straightforward way to challenge inaccurate locations, affiliations, or exclusions.
🔹 Recognize essential services. Explain the services your pharmacy provides, including compounding, hospice support, assisted living services, after-hours assistance, or same-day delivery. A nearby pharmacy may not offer the same services.
📊 Make your comments local and specific! Include your pharmacy's name and location, examples comparing driving and straight-line distances, transportation barriers, and how these factors affect patient access. Do not include identifying patient information.
📩 HOW TO SUBMIT:
Email: [email protected]
Subject: Draft Program Instructions – Affiliated Retail Pharmacy Data Collection
📅 Deadline: November 19, 2026, at 11:59 p.m. ET
📄 Review CMS's draft instructions:https://www.cms.gov/files/document/program-instructions-identifying-essential-pharmacies-affiliated-retail-pharmacy.pdf
Thank you for helping ensure CMS's methodology reflects the realities of pharmacy access across Arkansas!