Arlington, Va. December 23, 2013
– In comments
to the Centers for Medicare & Medicaid Services (CMS) today, the National Association of Chain Drug Stores (NACDS) backed a pharmacy-specific recommendation by the agency that would improve the January 1 roll-out of exchange-based insurance coverage. NACDS also urged additional steps that it considers necessary to improve the experience of the newly insured and existing patients alike, especially in the early days of the launch of insurance coverage under the Affordable Care Act (ACA).
“We welcome the additional millions of Americans who will have new insurance coverage. We are committed to working with all parties to address challenges and to maximize the experience of patients – similar to the efforts of community pharmacy that were noted as vital to smoothing the transition during the rollout of Medicare Part D,” NACDS wrote to CMS.
NACDS’ comments responded to an interim final rule extending health insurance exchange and premium payment deadlines, and taking steps to ease transitions as exchange-based insurance coverage begins.
NACDS expressed support for CMS’ encouragement of plans to cover a patient’s existing non-formulary drugs as if they were formulary drugs for the first 30 days of coverage after January 1, 2014. The Association also welcomed CMS’ urging that plans treat out-of-network providers as in-network providers during the initial months of enrollment, to address situations in which an out-of-network provider was listed as in-network at the time of enrollment or is providing treatment for an acute episode of care at the start of the year. NACDS urged CMS to be clear that pharmacies are included in these recommendations.
With a focus on the experience of patients, NACDS made several recommendations given other actions taken in the interim final rule.
“It will be important to empower patients with information that will be necessary to maximize their experience and ultimately to foster utilization of the benefits that will improve their health,” NACDS wrote.
“We are concerned that the initial enrollment deadline extensions may result in some newly insured patients not having the information necessary to process pharmacy claims for them in January. We are also concerned that some patients who enroll in a plan and take the opportunity to pay January premiums later in January may not be aware that they must pay for their health care and prescription drug services out-of-pocket pending payment of their insurance premium. In light of our concerns, NACDS urges CMS and insurers to engage in consumer education and outreach to address and mitigate these scenarios, offer ample support for pharmacies via call centers throughout the holidays, and use techniques that helped to ease the transition for the initial enrollment in Medicare Part D.”
In addition to working with member companies to advocate for steps that would maximize the experience for patients during the launch of exchange-based insurance, NACDS will be gaining insights from members throughout the roll-out and recommending any further actions that may be necessary to optimize patient experiences.