The December 2025 updates to the Site Visit Protocol included the following note:
“If patients pay a pharmaceutical dispensing fee, the dispensing fee is a service charge (not a supply) and is on the fee schedule. Prescription drugs are supplies that are related to, but NOT included in, the service itself as part of prevailing standards of care for the service and, therefore, are not on the fee schedule.”
During a March 5, 2026 webinar, HRSA suggested it intends to further modify this language, characterizing the pharmaceutical dispensing fee as a form of an operational expense that does not need to be included in the fee schedule and accordingly discounted in accordance with the sliding fee discount program.
Stay tuned for additional Site Visit Protocol revisions regarding pharmaceutical dispensing fees.
“If patients pay a pharmaceutical dispensing fee, the dispensing fee is a service charge (not a supply) and is on the fee schedule. Prescription drugs are supplies that are related to, but NOT included in, the service itself as part of prevailing standards of care for the service and, therefore, are not on the fee schedule.”
During a March 5, 2026 webinar, HRSA suggested it intends to further modify this language, characterizing the pharmaceutical dispensing fee as a form of an operational expense that does not need to be included in the fee schedule and accordingly discounted in accordance with the sliding fee discount program.
Stay tuned for additional Site Visit Protocol revisions regarding pharmaceutical dispensing fees.
For more information, please contact:
Carrie Riley
carrie.riley@powerslaw.com
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