Regulations & Laws
DIR Fees
Direct and Indirect Remuneration
Price concessions and incentive payments in Medicare Part D that adjust a pharmacy’s final reimbursement after the point of sale. Reforms moved these concessions to the point of sale beginning January 1, 2024.
In depth
Historically, PBMs and Part D plans collected DIR (direct and indirect remuneration) fees weeks or months after a claim, making true reimbursement hard to predict. Under a CMS final rule, beginning January 1, 2024 all price concessions a plan can reasonably determine must be reflected in the negotiated price at the point of sale, improving transparency. DIR remains a contract and reconciliation topic pharmacies monitor closely.