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Pharmacy coalition hails proposed Part D changes
February 26th, 2014
ALEXANDRIA, Va. – Amid rising concerns about the growth of preferred pharmacy networks, dozens of chain drug, supermarket and independent pharmacy operators are among 151 organizations endorsing provisions in the Centers for Medicare & Medicaid Services' proposed regulation for 2015 Medicare Part D prescription drug plans.
The organizations on Tuesday sent a letter to CMS administrator Marilyn Tavenner to express their strong support for provisions addressing prescription drug pricing, preferred pharmacy providers and the Part D benefit for medication therapy management (MTM).
One of the organizations, the National Community Pharmacists Association, noted that the letter comes as more congressional lawmakers contact CMS to voice support for the agency's proposal to allow community pharmacies to participate as preferred pharmacy providers if they are willing to accept the contract offered by a drug plan.
"We applaud CMS for formally recognizing that, although the agency was led to believe that its costs via preferred pharmacy networks to be uniformly lower, CMS' own findings proved otherwise," the organizations said in the letter. "We support CMS' proposal to require Part D plan sponsors to offer terms and conditions for every level of cost sharing, including preferred cost sharing, to any willing pharmacy that will accept the terms.
"This proposal will benefit seniors by giving them more choice among pharmacies in their drug plan and will lead to increased competition in the marketplace," they added.
Currently under preferred pharmacy drug benefit plans, most pharmacies can participate as network pharmacies to meet Medicare's geographic access requirements, but only a limited number of pharmacies are designated as preferred and are authorized to offer the plan’s lowest advertised co-pays, according to NCPA.
The association also has pointed out that the rising number of preferred pharmacy plans is challenging for seniors in rural areas, given that independent or regional drug stores are often the closest pharmacy and the nearest preferred pharmacy may be 20 miles or more away.
"CMS may request that Part D plans increase the number of pharmacies offering preferred, or lower, cost sharing as we are concerned that some plans that offer preferred cost sharing do not provide beneficiaries with sufficient access to the lower cost sharing at select network pharmacies," CMS said in announcing 2015 payment and policy updates for Medicare health and drug plans. "The intent of this policy will be to ensure that beneficiaries are not misled into enrolling in a plan only to discover that they do not have meaningful access to the advertised lower cost sharing."
In their letter to CMS, the organizations also hailed the agency's proposed expansion of the MTM benefit under Part D. In particular, the provision would increase the number of beneficiaries eligible for MTM services to those who have multiple chronic diseases, are taking multiple Part D drugs, and are likely to incur annual Part D drug costs that meet or exceed a certain threshold.
Other changes would improve the standard format for summaries of comprehensive medication reviews (CMRs) and ensure compliance with regulations and guidance. Overall, according to CMS, the changes are also aimed at fostering standardization among MTM programs, improving the integrity of data for the Part D Star Rating for MTM, and using MTM services to reduce the overuse of opioids.
"MTM services are critical to patient understanding and adherence to their medication regimens and are ideally provided face to face by a pharmacist," the organizations said in their letter. "We fully support the agency's efforts to expand access to these critical services and agree with CMS that MTM must become a cornerstone of the prescription drug benefit and that studies have shown the positive impact on patient outcomes and costs that MTM provides."
The organizations, too, applauded CMS' interpretation of the noninterference provision and timely updates to drug pricing standards.
"We agree the Medicare Modernization Act noninterference provision was intended to address negotiations related to the selection of drug products that would be covered under Part D formularies, and was not meant to prohibit CMS guidance that ensures the Part D marketplace operates in a fair and efficient fashion," they wrote in the letter. "We commend CMS for recognizing additions to what constitutes a 'prescription drug pricing standard.' We support CMS' expectations that pharmacies should have current data on the amount of reimbursement they can expect, which in turn impacts costs that plan sponsors submit to CMS as well as prices displayed on Plan Finder."
More than 50 pharmacy operators were among those signing the letter to CMS. They included such drug chains as Astrup Drug, Aurora Pharmacies, Bartell Drugs, Care Pharmacies, Discount Drug Mart, Fagen Pharmacy, Fruth Pharmacy, Hartig Drug, Hi-School Pharmacy, HomeTown Pharmacy, Kinney Drugs, Kopp Drug, Lifecheck Pharmacies, Navarro Discount Pharmacy, Osborn Drugs, QuickChek Pharmacies, Ritzman Pharmacies, Sav-Mor Drug Stores, Sav-On Drugs and Thrifty White Pharmacy
Others sigining the letter included supermarket retailers such as Associated Fresh Markets, Bashas', Big Y Foods, Brookshire Grocery, Haggen, Hy-Vee, King Kullen, Raley's, ShopRite and Weis Markets, as well as state pharmacy associations and pharmacy buying groups, suppliers and service providers.
"We want to take this opportunity to voice our strong support for certain proposed changes to the Medicare Part D prescription drug program that will allow more meaningful beneficiary choice and increased marketplace competition," the organizations said in the letter to CMS. "The undersigned organizations represent key health care providers who have been on the front lines of providing medications and related counseling to Medicare beneficiaries since the inception of the Part D program, as well as drug supply chain participants."
Recently, community pharmacies recently have generated increased congressional support in addressing their concerns about preferred pharmacy networks. Last March, 31 Congressmen sent a letter to CMS to express concerns over preferred networks in Part D. The lawmakers stated, "We fear these networks could lead to a decrease in access to quality care and threaten the survival of community pharmacies." Shortly thereafter, CMS received a similar letter from 16 U.S. senators.
And on Monday, Rep. Doug Collins (R., Ga.) sent a letter to CMS chief Tavenner that highlighted challenges that preferred networks present to community pharmacies.
"Independent community pharmacy owners in my district have contacted me with problems they are facing in light of being excluded from these preferred networks. In many cases, independent and community pharmacists have dedicated their careers to providing quality patient care, but exclusion from preferred networks has resulted in a strain on their patients and their businesses," Collins wrote. "I was pleased to see that your agency's proposed rule on Part D included promising language that addresses some of the concerns laid out in the [March 2013] letter.