Arlington, Va. March 12, 2014
– Citing pharmacist-administered medication therapy management (MTM), recognition of pharmacists as healthcare providers, the need for fair and accurate pharmacy reimbursement in state Medicaid programs and other pharmacy services, the National Association of Chain Drug Stores (NACDS) urged lawmakers to carefully consider pharmacy provisions within the “Fiscal 2015 Budget,” released by the Administration last week.
NACDS submitted a statement
to the House Budget Committee and House Ways and Means Committee as each begins review of the “Fiscal 2015 Budget” during hearings this week. “Community pharmacies and pharmacists provide access to prescription medications and over-the-counter products, as well as cost-effective health services such as immunizations and disease screenings,” NACDS stated in its comments. “Through personal interactions with patients, face-to-face consultations and convenient access to preventive care services, local pharmacists are helping to shape the healthcare delivery system of tomorrow—in partnership with doctors, nurses and others.”
In its statement, NACDS cited public and private studies showing the health benefits and cost-savings as a result of pharmacist-provided MTM services, including a 2013 report by the Centers for Medicare & Medicaid Services (CMS) which found that Part D MTM programs consistently and substantially improved medication adherence and quality of prescribing for evidence-based medications for beneficiaries with congestive heart failure, COPD, and diabetes.
“Moreover, policymakers have begun to recognize the vital role that local pharmacists can play in improving medication adherence. Congress has recognized the importance of pharmacist-provided services such as MTM by including it as a required offering in the Medicare Part D program,” NACDS stated in its comments.
Highlighting pharmacists’ proven ability to provide services that lead to better clinical outcomes and lower healthcare costs, NACDS urged the “implementation of budget proposals that allow all healthcare providers, including retail pharmacists, to practice to their maximum capabilities, working in partnership to provide accessible, high quality care to patients.”
Focusing on patient access to care, NACDS expressed its opposition to the Department of Health and Human Services (HHS) proposal within the FY2015 Budget to exclude brand and authorized generic drugs from the calculation of average manufacture price (AMP), thereby calculating Medicaid Federal Upper Limits (FULs) based only on generic drug prices.
“While the goal of this provision may be to decrease Medicaid costs, we believe it may in fact reduce access to prescription drugs and pharmacy services for Medicaid patients, resulting in increased overall healthcare expenditures,” NACDS stated in its comments.
NACDS’ recent analysis, indicated that approximately 35 percent of the draft FULs are below National Average Drug Acquisition Cost (NADAC).
“This analysis confirms that additional efforts by CMS are necessary to ensure that pharmacies are not reimbursed below their costs using the reimbursement formula created by the Affordable Care Act. We urge CMS to utilize the rulemaking process to implement the Medicaid pharmacy provisions in a manner consistent with congressional intent, rather than pursuing policies that would further cut pharmacy reimbursement,” NACDS stated in its comments. NACDS also stressed the implications on patient care if CMS pursues changes to Medicaid reimbursement of durable medical equipment (DME) specifically for diabetes testing supplies (DTS).
“Reducing Medicaid reimbursement for DTS to match the Medicare rate could similarly produce hardships for Medicaid beneficiaries in terms of reducing access to needed supplies and threatening the health of an already fragile population.
In its statement, NACDS also expressed support for provisions to increase the utilization of generic drugs which help control prescription drug costs; and stressed cautious support for efforts by HHS to reduce waste, fraud and abuse in the Medicare and Medicaid programs, but in a manner that does not to disrupt beneficiary access or jeopardize beneficiary health.
“We look forward to working with policymakers and stakeholders on these important issues,” NACDS concluded in its statement.