NCPA reiterates call for 'any willing pharmacy' policy in Part D

ALEXANDRIA, Va. — Though the Centers for Medicare & Medicaid Services (CMS) has improved Medicare Part D patient access to preferred pharmacies, more work needs to be done, according to the National Community Pharmacists Association.

NCPA on Friday applauded a statement released by CMS that the agency’s efforts to boost access to preferred pharmacies across a wider geographical range have borne fruit.

“Last year, we heard concerns that some beneficiaries did not have ready geographic access to preferred cost-sharing pharmacies. Increasingly, Part D plans are creating smaller networks of pharmacies within their larger networks and offering lower cost-sharing arrangements to beneficiaries who use these preferred cost-sharing pharmacies. Plans market these lower cost-sharing arrangements, which are appealing to beneficiaries looking to save money on their prescription drugs. However, in some instances, these pharmacies were not geographically accessible to the beneficiaries in the plan,” Sean Cavanaugh, deputy administrator and director of the Center for Medicare at CMS, said in the statement.

“We are pleased to share that, based on data we are posting on CMS.gov, access to preferred cost-sharing pharmacies has improved,” he noted. “The bottom 10th percentile of plans in 2016 offer access within two miles to 71% of urban beneficiaries, as compared to 40% of beneficiaries in 2014.”

B. Douglas Hoey, chief executive officer of NCPA, said the association appreciates CMS’ efforts and that, at this time, it’s still reviewing the full CMS analysis.

CEO B. Douglas Hoey, RPh, MBA issued the following statement today in response to the detailed “preferred pharmacy” access analysis released by the Centers for Medicare & Medicaid Services (CMS) and conducted in response to concerns raised by NCPA, beneficiary advocates and others:

“Our initial reaction is that more work must be done in this area,” Hoey stated. “The CMS analysis documents progress yet still identifies many plans that are ‘access outliers’ that impact a significant number of beneficiaries. Indeed, this total could be higher because CMS excluded from this analysis plans granted waivers to the retail pharmacy convenient access standard requirement. The marketing disclaimers, while appreciated, come well after the 2016 enrollment period concluded and six weeks into the plan year.”

Hoey also noted that the format in which that data is posted should be more accessible to Medicare beneficiaries and their caregivers, and he urged that this information be incorporated into Medicare Plan Finder, particularly before beneficiaries research their enrollment decisions.

He also called for “swifter relief and protection” for Part D beneficiaries.

“To that end, we encourage Medicare officials to implement an ‘any willing pharmacy’ policy and Congress to enact H.R. 793/S. 1190,” Hoey commented. “This would allow beneficiaries in medically underserved areas to access their prescription drugs at a community pharmacy that accepts the drug plan’s terms and conditions and can serve those patients. Medicare officials have already acknowledged that this is ‘the best way to encourage price competition and lower costs in the Part D program.’ “

Cavanaugh reported that in CMS’ analysis of Part D beneficiary access to preferred cost-sharing pharmacies, released last April, the agency was “pleased to learn” that most Part D enrollees live in areas where Part D plans provide “reasonably robust” preferred pharmacy networks.

“However, some beneficiaries in all areas — but particularly those in urban areas — face limited or in some instances no geographic access to preferred cost-sharing pharmacies,” he observed.

CMS took action on those findings in last year’s Medicare Advantage rate notice and Part D call letter, according to Cavanaugh. He noted that in the letter, the agency said it would work with outlier plans to address our concerns about access and marketing; require plans whose preferred cost-sharing networks are outliers (i.e. offering much less access to preferred cost-sharing pharmacies) in 2016 to disclose in marketing materials that their plan offers less access; and publish access levels for each plan offering a preferred cost sharing benefit structure.