Talk Infusion | CMS Requests Information on Part D Contracting Standards - 10/8/2026

CMS released a request for information (RFI), “Medicare Part D Reasonable and Relevant Pharmacy Contracting Standards.” The RFI will be used to inform future rulemaking to implement the requirements under the Consolidated Appropriations Act of 2026 (CAA, 2026) that Part D sponsors permit any pharmacy that meets the Part D plan’s standard contract terms and conditions to participate as a network pharmacy. CMS seeks input on several topics, including:

Pharmacy reimbursement and dispensing fees.
Current pharmacy contracting practices.
Trends in Part D plan sponsor and network contract terms and conditions.
Pharmacy quality and performance measures.
Part D plan sponsor auditing practices.
Plan sponsor restrictions or limitations on network pharmacies’ dispensing of covered Part D drugs.
Current regulations or Part D guidance related to contracting that may require clarification or additional details.
Other relevant information such as operational considerations.

Also, learn how you can contribute to NHIA's comments to CMS.

Connie Sullivan

President & CEO

National Home Infusion Association

Connie Sullivan, B.S.Pharm, is the President and CEO of NHIA. Sullivan has over 25 years of infusion industry leadership, management, and clinical practice experience. Sullivan is responsible for NHIA’s advocacy initiatives and developing resources that support the infusion industry to foster innovation and promote the delivery of high-quality care. Sullivan also oversees the National Home Infusion Foundation, a 501c3 devoted to infusion research and developing future leaders. Sullivan is a member of the United States Pharmacopeia (USP) Sterile Compounding Expert Committee and currently Chairs the <797> Subcommittee. Sullivan earned her pharmacy degree from The Ohio State University in 1994.

NHIA Requires planners, faculty, and others who affect the content of this activity to disclose all financial relationships they have with ineligible companies. All relevant financial relationships are thoroughly vetted and mitigated according to policy.

Connie Sullivan has no relevant financial relationships with ineligible companies to disclose.

Bill Noyes

Sr VP of Reimbursement Policy

NHIA

Bill Noyes is the Senior Vice President of Reimbursement Policy at the National Home Infusion Association (NHIA). He joined NHIA in 2012 as Vice President of Health Information Policy, focusing on reimbursement and regulatory issues affecting providers' ability to do business and collect payment for their services. Noyes sits on four Medicare Contractor Advisory Councils and is the liaison to NHIA's reimbursement-focused committees. He also works closely with the NHIA government relations team to gain more meaningful Medicare coverage for home infusion. He served as Interim CEO of the associaiton from July 2018 to November 2018. Prior to joining NHIA, Noyes spent 20 years as Vice President of Operations for a multi-state home infusion provider where he was responsible for purchasing, distribution, facilities, revenue cycle management, and pharmacy operations.

Bill Noyes has no relevant financial relationships with ineligible companies to disclose.