Alexandria, Va. Feb. 26, 2014
- Proposed improvements to the Medicare Part D prescription drug program would give seniors greater pharmacy choice and competition at no added cost while remaining consistent with existing Medicare statute, well-documented congressional intent and a series of previous, bipartisan actions by Congress and prior Administrations, the National Community Pharmacists Association
(NCPA) said today in a statement for the record
for a hearing of the U.S. House Energy and Commerce Subcommittee on Health.
"Independent community pharmacists support the pro-patient provisions of Medicare's proposed rule because they offer more choice and pharmacy competition for beneficiaries at no added cost to the Medicare program or taxpayers," said NCPA CEO B. Douglas Hoey, RPh, MBA. "Independent community pharmacists have been vital health care providers since the first days of the Medicare Part D benefit. We look forward to continuing to work constructively with Medicare and Congress to ensure that this program effectively serves seniors while safeguarding taxpayer dollars."
NCPA's comments reinforced to lawmakers the following aspects of the Centers for Medicare & Medicaid Services (CMS) proposed rule for 2015 Part D drug plans:
More pharmacy choice for seniors and pharmacy competition at no added cost. Many seniors have signed up for "preferred pharmacy" plans without realizing that they could no longer use their pharmacy of choice. Medicare's proposal would allow more pharmacies the opportunity to participate as "preferred" providers if they are willing to accept the contract offered by a drug plan. This would particularly benefit seniors in underserved rural areas who may have to bypass an independent community pharmacy while traveling 20 miles or more to reach a "preferred pharmacy."
The current "preferred pharmacy" system is NOT necessarily less expensive to the consumer OR the federal government. Contrary to CMS' initial assumptions and the claims of pharmacy benefit managers (PBMs), CMS' own analysis and cost comparisons using the Medicare Plan Finder website indicate that Medicare and taxpayers often pay more when prescription drugs are obtained through preferred pharmacy networks and mail order pharmacies than they would if the same prescriptions were filled through other "non-preferred" pharmacies.
Expansion of access to critical medication therapy management (MTM) programs leading to improved outcomes and reduced costs. NCPA supports the expansion of access to these critical MTM services and agrees with CMS that MTM must become a cornerstone of the Prescription Drug Benefit.
Updating pharmacy reimbursement to account for soaring drug costs. CMS' proposal would help ensure plans' reimbursement of community pharmacies better reflects market costs. Currently, the acquisition costs for many generic drugs are increasing by 600%, 1,000% or more practically overnight while PBMs may wait several months before updating their reimbursement—and almost never retroactively.
Reducing potential fraud, waste, and abuse. The proposed rule calls for PBMs to engage an outside auditor to confirm they are complying with CMS regulations. Currently, there is little oversight of complex multi-billion-dollar PBMs in this taxpayer funded program.
CMS correctly interprets the "non-interference" provision. The congressional intent behind the "non-interference" provision precludes CMS' interference between prescription drug plan (PDP) sponsor and drug manufacturer negotiations over drug coverage or pricing decisions. The provision does not preclude the agency's responsibility to ensuring that the Part D marketplace operates in a fair and efficient fashion between PDPs and pharmacies.
The proposed rule is consistent with past precedents. Congress and prior Administrations have taken action numerous times in the past to provide common sense guidelines governing the plan sponsor/pharmacy relationship in the part D program, including the congressional enactment and CMS enforcement of "prompt pay" provisions requiring timely reimbursement for legitimate claims.
For more information on the proposed rule, go to www.ncpanet.org/medicare