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The Pharmacy List That Cleared OMB Before Your Rate Book

OMB concluded its review of CMS's draft program instructions for identifying essential retail pharmacies on October 8, seventeen days after they arrived, and cleared them Consistent with Change. The four CY 2027 payment rules that set your rates are still in the queue at 24, 24, 20 and 12 days. The statute behind the pharmacy file carries a plan year 2027 reporting date, 82 days out. Also in the window: a surveyor worksheet that now collects the CCN of every provider you are affiliated with, and two more rural transformation packages.


Sixteen CMS documents went into OMB's executive-order review queue and stayed there. We counted them on October 7 and again on October 9: the same sixteen, nothing concluded, nothing new arriving.

This morning there are fifteen.

The one that left is not a rate book. It is a set of draft program instructions for identifying every retail pharmacy with no competitor within a mile, and for making every Part D sponsor hand over the pharmacies it and its PBM own.

The notice that got out

RIN 0938-ZC08 reached OMB on September 21 under the title "Draft Program Instructions for Identifying Essential Pharmacies and Affiliated Retail Pharmacy Data Collection". Its per-RIN record now reads concluded October 8, conclusion action "Consistent with Change".

Seventeen days, door to door.

The pending listing we pulled on October 9 still carried it, so this is the first thing to leave that queue since we started reading it on October 7.

The rest of this brief is for subscribers.

The impact tables, the code-level detail, and the rest of the analysis sit past this line.

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