The National Asssociation of Chain Drug Stores submitted comments on the security of the prescription drug supply chain and patient pharmacy access in the TRICARE military health plan for a pair of congressional committee hearings.

National Asssociation of Chain Drug Stores, NACDS, prescription drug supply chain, TRICARE, Drug Quality and Security Act, drug distribution supply chain, community pharmacies, chain pharmacies, retail pharmacies, House Appropriations Agriculture Rural Development Food and Drug Administration Related Agencies Subcommittee, illegal Internet drug sellers, chokepoint approach, Senate Committee on Armed Services, TRICARE Mail Order Pharmacy, pharmacy access

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NACDS gives Congress its take on Rx supply chain, TRICARE

March 27th, 2014

ARLINGTON, Va. – The National Asssociation of Chain Drug Stores submitted comments on the security of the prescription drug supply chain and patient pharmacy access in the TRICARE military health plan for a pair of congressional committee hearings.

NACDS said it provided a statement in the lead-up to Thursday's hearing by the House Appropriations Agriculture, Rural Development, Food and Drug Administration, and Related Agencies Subcommittee, which was titled "Budget Hearing: Food and Drug Administration."

In its statement, NACDS cited pharmacy's work to help shape the Drug Quality and Security Act, its ongoing advocacy and engagement in the implementation of the new law, and its long-term efforts to safeguard the drug distribution supply chain.

"Chain pharmacies wholeheartedly support efforts to secure the U.S. drug distribution supply chain. They have invested significant resources and efforts towards this goal over many years, including changes in their purchasing practices, and actively supporting state legislation that strengthened supply chain integrity," NACDS said in its statement.

NACDS emphasized the need to thwart illicit Internet drug sellers to help protect consumers from counterfeit and adulterated medications. The association also recognized the FDA's efforts to educate consumers and health care providers about the risks of illegal online drug sellers.

"We support targeting illegal Internet drug sellers through the chokepoint approach. Under this approach, Internet service entities and companies such as domain name registrars that issue websites, financial entities that handle payment transactions for online sales, Internet service providers that provide information from the Internet, and common carriers that provide the mailing services would have authority to stop illicit transactions at their point of interaction with these bad actors,” NACDS stated.

NACDS also urged Congress and the FDA to provide an Internet portal so consumers and health providers could check if a website offering to sell medications is legitimate.

The association, too, called on Congress to provide the FDA with funding necessary to establish an abbreviated approval pathway for biosimilars and interchangeable versions of biological products.

"For the benefit of the patients we serve, we have urged the agency to make establishing this pathway among its highest priorities," NACDS said in the statement. "Increasing generic drug utilization is one of the most effective ways to control health care costs."

In a statement for a Wednesday hearing by the Senate Committee on Armed Services, Subcommittee on Personnel, NACDS urged lawmakers to preserve pharmacy access and choice for TRICARE patients.

NACDS' comments expressed concerns about proposed changes to pharmacy co-payments in President Obama's fiscal 2015 budget that would shift TRICARE patients away from local pharmacies and into the TRICARE Mail Order Pharmacy program. That would limit the ability of beneficiaries to obtain nonformulary medications from their local pharmacies — which are not just reliable, convenient sources for obtaining prescriptions but also health care destinations, the association noted.

"NACDS supports cost savings initiatives that preserve patient choice, but threatening beneficiary access to prescription medications and their preferred health care provider will only increase the use of more costly medical interventions, such as physician and emergency room visits and hospitalizations," the association said in its statement to the committee.

The Department of Defense (DoD) has also recognized the cost-effectiveness of pharmacist-provided immunizations and has authorized TRICARE patients to get vaccinations at a retail network pharmacy for a $0 co-pay, according to NACDS. In the DoD's final rule expanding the authority of retail pharmacies to provide vaccines, the department cited savings of almost $1.5 million by expanding the portfolio of vaccinations that TRICARE patients may obtain from community pharmacies.

"Ensuring that TRICARE beneficiaries have ready access to vaccine supplies allocated to private sector pharmacies will facilitate making vaccines appropriately available to high risk groups of TRICARE beneficiaries," NACDS stated.