NACDS’ comments take issue with a proposed rule that would repeal the approach by which states demonstrate and ensure compliance with federal “access requirements.” Medicaid patients must have access to health care services at least on par with those available to a geographic area’s general population.
“CMS must maintain a standardized, transparent process for states to determine if they are meeting federal access requirements,” wrote NACDS president and chief executive officer Steven Anderson, in the comments.
Among NACDS’ concerns is the importance of network adequacy for Medicaid patients, and its comments state that “any changes to state requirements to demonstrate compliance with access standards should include policies to ensure that patients will continue to have access to their current providers and pharmacies of choice.”
“Restricting provider networks result in restricted patient ability to access their health care providers and unnecessary disruptions in needed care,” NACDS stated. “As a result, there is the potential for increased overall healthcare expenditures due to the use of more costly healthcare services among Medicaid patients.”
NACDS’ comments detail the value of pharmacy in state Medicaid programs, including a clear statement that “it is important for CMS to know that ensuring access lowers overall state costs.” NACDS detailed the relationship between pharmacy access and medication adherence, or the higher likelihood that patients take their medications as prescribed and thus avoid emergency room visits and hospitalization.
NACDS also emphasized the value of newer pharmacy services, such as vaccinations, health education, point-of-care and disease-state testing, disease management, and medication synchronization.
“Pharmacists are even more highly valued by those that rely on them most – older Americans, individuals managing chronic diseases, and those in urban, rural and underserved areas. Pharmacy services improve quality of life and healthcare affordability,” NACDS commented.
In addition to the ramifications on patient care, NACDS explained that the proposal violates rules that govern the policymaking process. For example, the Administrative Procedure Act requires that in order to repeal or suspend a regulation, an agency must provide a reasoned explanation that meets specific qualifications. NACDS noted that the proposed rule does not fulfill this requirement.
More information about NACDS’ public policy positions are available on the NACDS Access Agenda website.