VALLEY FORGE, Pa. — AmerisourceBergen Corp., working in concert with its industry trade association, the Healthcare Distribution Alliance, has proposed a comprehensive framework that would support a proposed move from the current pharmaceutical rebate system to point-of-sale (P-O-S) discounts, in response to the Department of Health and Human Services’ (HHS’) Notice of Proposed Rule Making regarding the Removal of Safe Harbor Protection for Rebates Involving Prescription Pharmaceuticals.

The company said it supports policies that lower out-of-pocket costs for patients and stands ready to support a transition to a patient-centered model with distributors serving as chargeback administrators for a January 1, 2020, start.

“As the connector of pharmaceutical innovators and health care providers, distributors are uniquely positioned to support the seamless and efficient delivery of P-O-S discounts to Medicare beneficiaries,” said AmerisourceBergen chairman, president and chief executive officer Steve Collis. “We come prepared with solutions that are fair, efficient and transparent, and that’s why we believe we are best positioned to lead this transition.”

The company said a distributor-facilitated model would focus on:

• Relationships built on trust: Pharmaceutical distributors have strong service-oriented relationships, built on fairness and trust, with their pharmacy customers and manufacturer partners. These long-standing relationships allow distributors to approach this reform in a fair and equitable way to meet the needs of all stakeholders, and, most important, create a positive impact for patients. Further, since pharmacies are important customers for wholesalers, it is in distributors’ best interest to ensure that pharmacies promptly receive P-O-S discounts. In addition, distributors have no role in setting the price of brand pharmaceuticals and do not influence formulary decision making.

• Proven experience and infrastructure: Distributors and manufacturers manage and maintain complex contract administration and chargeback systems today that enable manufacturer discounts for health system customers. In 2018 alone, AmerisourceBergen exchanged over 300 million chargeback transactions with manufacturers with greater than 99% successfully completed in three business days or less. Extending this proven chargeback system to handle P-O-S discounts would be a natural evolution.

• Commitment to transparency: Chargebacks would be processed with full visibility and auditability by all stakeholders. Further, given the existing direct financial relationships with both manufacturers and providers, distributors could facilitate chargebacks through adjustments to their accounts payable to manufacturers and accounts receivable from pharmacies, resulting in cashless transactions.

To further operationalize, pharmaceutical distributors would, directly or indirectly from their customers, secure the requisite chargeback detail from the P-O-S claims and provide an efficient and effective process for manufacturers to make pharmacies whole, meeting or exceeding the mandatory 14-day prompt pay ­requirement.