ALEXANDRIA, Va. — The National Community Pharmacists Association has submitted comments to a trio of federal agencies to emphasize patient choice and greater use of generic drugs as they devise criteria for maintaining Grandfathered Health Plan (GHP) status under the Patient Protection and Affordable Care Act (PPACA).
NCPA said Tuesday that it provided input on pharmacy benefits to the Internal Revenue Service, Employee Benefit Security Administration (EBSA), and the Department of Health and Human Services Office of Consumer Information and Insurance Oversight (OCIIO) as they assess the guidelines for GHP status for the recently enacted health care reform law.
Douglas Hoey, acting executive vice president and chief executive officer of NCPA, noted that health plans looking to uphold GHP status shouldn’t be permitted to alter their structure and benefits in a way that undermines patient care, including pharmacy services.
"For example, the face-to-face interaction patients get in their local pharmacies has a proven, positive track record in terms of health outcomes," Hoey said in a statement. "Changes by health plans that steer patients against their will toward mail order pharmacies represent more than just ‘reasonable routine changes’ to an existing health plan and should cause them to lose grandfathered health plan status."
"Similarly, health plans should not be able to maintain grandfathered status when they change their prescription drug formulary designs by creating or expanding a list of ‘specialty medications’ in order to shift patients to a specific mail-order pharmacy," he explained, noting that such changes will lead to more limited beneficiary access to those medicines.
"Specialty medications are likely not available to independent community pharmacies," Hoey stated. "These are more than ‘reasonable routine changes’ and should also cause them to lose their grandfathered status."
However, adjustments to a formulary upon the introduction of generic options would be acceptable changes, according to Hoey.
"When generic alternatives become available, the brand-name prescription drug is routinely placed in a higher co-pay tier in the drug formulary to promote the use of the generic," he said. "That is indeed a ‘reasonable routine change’ and should not be grounds for a plan losing its grandfathered status."
