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ALEXANDRIA, Va. The National Association of Chain Drug Stores on Tuesday released a letter addressed to the Internal Revenue Service requesting clarifications of provisions regarding over-the-counter and prescription medications in the Patient Protection and Affordable Care Act.
First and foremost, NACDS is concerned that current IRS guidance would prohibit the use of debit cards in the purchase of not only any prescribed OTC medicine, but also any prescription-only therapy.
“Currently, there is no robust interaction between pharmacy dispensing systems and [inventory information approval systems; the systems used to substantiate purchases for flexible spending accounts]; an IIAS cannot distinguish between a medication for which a prescription is required and an OTC that has been prescribed,” NACDS explained. “As a result, a prohibition on using debit cards for prescribed OTC medications could have the practical effect of prohibiting the use of debit cards for all prescribed medications. … IRS’ prohibition on using debit cards for prescribed OTC medications greatly diminishes the value of the IIAS infrastructure unless pharmacies invest even more capital to modify the IIAS infrastructure to comply with the new guidance.”
There is significant capital at stake, NACDS argued, as the IIAS modifications to distinguish prescription-only and OTC across all stakeholders could take as long as two years to implement. NACDS requested IRS allow the use of debit cards to purchase prescribed OTCs; otherwise, the association requested that the two-week delay the IRS has allowed for implementation be extended by two years.