"In cases where a pharmacy offers a lower price to its customers throughout a benefit year, this would not constitute a "lower cash price" situation that is the subject of this guidance.
For example, Walmart and other retailers recently introduced programs offering a reduced price for certain generics to its customers.
The low Walmart price on these specific generic drugs is considered Walmart’s “usual and customary” price, and is not considered a one-time "lower cash" price.
Part D sponsors consider this lower amount to be “usual and customary” and will reimburse Walmart on the basis of this price.
To illustrate, suppose a Plan's usual negotiated price for a specific drug is $10 with a beneficiary copay of 25% for a generic drug.
Suppose Walmart offers the same generic drug throughout the benefit for $4.
The Plan considers the $4 to take the place of the $10 negotiated price.
The $4 is not considered a lower cash price, because it is not a one-time special price.
The Plan will adjudicate Walmart’s claim for $4 and the beneficiary will pay only a $1 copay, rather than a $2.50 copay. This means that both the Plan and the beneficiary are benefiting from the Walmart “usual and customary” price, and the discounted Walmart price of the drug is actually offered within the Plan’s Part D benefit design.
Therefore, the beneficiary can access this discount at any point in the benefit year, the claim will be adjudicated through the Plan's systems, and the beneficiary will not need to send documentation to the plan to have the lower cash price count toward TrOOP."