ALEXANDRIA, Va. — The National Community Pharmacists Association has endorsed new proposed protections of patient choice of pharmacy and called on federal officials to take additional steps to support broader consumer protection at no added cost.
NCPA said Tuesday that its comments come in response to a range of new requirements and recommendations proposed by the Centers for Medicare & Medicaid Services (CMS) for health insurance plans that operate in the exchanges established by the Affordable Care Act. The changes, if implemented, would apply to the 2016 plan year.
"We strongly support the proposed requirement that enrollees be provided with the option to access their prescription drug benefit through retail (bricks and mortar or non-mail order pharmacies) and that plans cannot have a mail order only prescription drug benefit," Susan Pilch, vice president for policy at regulatory affairs at NCPA, said in a statement. "In addition, we would like to propose that an additional provision be included that would allow a retail pharmacy to charge the same copay as the mail order pharmacy as long as the retail pharmacy agrees to accept the same reimbursement as the mail order pharmacy."
Other highlights of NCPA’s comments to CMS include the following:
• Plans that offer 90-day drug fills at mail order should be required to also offer 90-day drug fills at retail network pharmacies. "Many times, community pharmacies are willing to do so, at the same net cost to the health plan, but may be blocked from doing so by plan intermediaries known as pharmacy benefit managers (PBMs), many of which have a vested financial interest in establishing plan benefit designs that unfairly advantage their own mail order pharmacies," NCPA stated.
• Support of added protections for patients who wish to obtain specialty drugs from their community pharmacist instead of the PBM’s mail order pharmacy.
• Plans should update their listings of in-network providers more frequently, as CMS proposed. In addition, plans should allow the participation of all pharmacies willing to accept the requisite terms and conditions, and the TRICARE/Medicare Part D retail pharmacy access standards should apply to exchange plans as a minimum threshold for network adequacy, including any preferred networks of pharmacies authorized to offer further discounts.
• Agreement with CMS’ recommendation that plans more broadly cover services in the 30-day transition period as patients assimilate to a new plan.
"It is important to remember that the insurance marketplaces are going to be utilized mainly by a demographic that has had little or no access to health insurance, and in turn, access to health care services or prescription drug therapies. Therefore, this is a population that is likely to need a myriad of services immediately upon obtaining coverage. This is especially critical with regard to access to pharmacy care services," Pilch stated in the letter to CMS. "The New England Healthcare Institute (NEHI) has estimated that medication-related problems including poor adherence impose as much as $290 billion in annual costs, or 14 percent of healthcare expenditures. These costs include emergency room visits, hospitalizations, and other preventable forms of care. Ensuring adequate access to prescription medications can stave off many of these costly downstream interventions and provide an excellent return on investment."
