NACDS to HHS: Pharmacies key to value-based care

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ARLINGTON, Va. — The National Association of Chain Drug Stores has taken the fight for pharmacy care to an intriguing and potentially highly consequential arena. A federal agency will decide whether pharmacies should be included in the definition of “value-based enterprise (VBE) participant,” and NACDS’ comments answer that question with an emphatic yes.

In a proposed rule, the Department of Health and Human Services’ (HHS’) Office of Inspector General (OIG) invited feedback as to whether pharmacies should be excluded from the definition of “VBE participant.” The decision is being made on one specific point of regulatory policy that relates to the Anti-Kickback Statute, and its “safe harbors” that apply to providers instrumental in the coordination of care, rather than to those that primarily provide items. Exclusion from the definition would create yet another needless barrier to pharmacy patient care.

“Community pharmacies can and do play a critical role in coordinating and managing care for patients. As evidenced throughout our comments, community pharmacies should be included in the definition of ‘VBE participant.’ We urge OIG to remedy this misconception in the final rule,” wrote NACDS president and chief executive officer Steve Anderson.

“As you work through the HHS ‘Regulatory Sprint to Care’ to improve patient outcomes, produce health system efficiencies, lower costs and transform our nation’s health care system to better pay for value, we urge you to consider how community pharmacies are helping to accelerate your efforts. Moreover, we urge you to consider how community pharmacies could further accelerate your efforts through recognition in the proposed rule,” he added.

NACDS’ comments lay out a comprehensive case, with extensive citations of research validating the economic value of community pharmacy patient care. The comments also describe specific examples in which payers have recognized the value of pharmacy to improve quality and value, and incentivized pharmacies to deliver clinical care outside of dispensing prescriptions.

The association also urged officials to see the findings in Gallup’s latest measure of honesty and ethical standards as yet another call to leverage pharmacies more completely for patient health.

The Gallup survey, conducted in December, maintained pharmacy’s consistent position among the most highly esteemed professionals. Nearly two-thirds of Americans called pharmacists’ honesty and ethical standards “very high or high.”

“This latest Gallup survey is yet another important data point,” said Anderson. “Patients trust pharmacists and rely on their accessibility. Studies show that patients are more likely to do the things that keep them healthy when they have access to pharmacists and pharmacies. Studies also show the link between fair reimbursement policies, forward-thinking policies that improve access to pharmacy services and improved patient health. Together, we have built success stories that benefit patients.

“However, right now there are dire examples playing out of extremely flawed and unfair policies. They are threatening pharmacy access. These include direct and indirect remuneration (DIR) fees, broader examples of forcing pharmacies to fill prescriptions below cost, and other extremely damaging and unworkable policies. They also include unwarranted barriers to pharmacy care that is valued by patients. These issues need to be addressed urgently. It is a matter of fairness to pharmacies and to patients alike.”



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