NCPA Advocacy Center Update – Week Ending December 24, 2016

DEA Revises Registrant Renewal Policy:  Heeding the concerns of NCPA and other registrants, the DEA has quickly revised a recently-issued policy change on renewal applications that could have decreased patient access to controlled substances and had audit implications for pharmacies. Starting Jan. 1, DEA will no longer send its second renewal notification by mail. Instead, an electronic reminder to renew will be sent to the email address associated with the DEA registration. Otherwise, current renewal policy will be retained, including a limited grace period for one calendar month after the expiration date. If the registration is not renewed within that calendar month, an application for a new DEA registration will be required.

Pharmacy Groups Reach Out to Trump and New Leadership: NCPA and three other pharmacy associations (NACDS, APhA, NASPA) have detailed steps necessary to leverage pharmacy patient care and prevent higher costs that result from untreated health conditions. Their recommendations were made in a letter to the new political leadership in the nation’s capital. Written against the backdrop of the predicted repeal of the Affordable Care Act, potential conversion of Medicaid to a block grant program, and possible privatization of Medicare, the four associations said: “As the incoming Administration and Congress consider potential changes to the Medicare and Medicaid programs, we ask that you ensure that beneficiary access to pharmacies is protected. Policies that reduce local pharmacy access lead to poorer health outcomes, ultimately resulting in increased future health care costs.”

The joint letter highlighted the accessibility of pharmacists, their role in boosting medication adherence, and the importance of maintaining patients’ choice of pharmacies. It also stressed the importance of assuring fair and accurate Medicaid pharmacy reimbursement, according to average manufacturer price (AMP)-based federal upper limits (FULs) that were enacted in the Affordable Care Act; and opportunities to build on pharmacists’ vaccination success story by improving patient access to pharmacist services for underserved Medicare beneficiaries.

NCPA, Members of “AMP” Coalition Ask Congress to Retain Medicaid Pharmacy Reimbursement Policies:  In order to preserve Medicaid beneficiary access to needed medications and proper reimbursement for community pharmacies, five organizations are asking Congress to retain ACA Medicaid pharmacy reimbursement provisions.  NCPA, GPhA, NACDS, NASPA and HDA  reminded Congress that if the ACA Medicaid provisions are repealed in total the Deficit Reduction Act would become the new foundation for Medicaid reimbursement.  This would lead to negative impacts on many Medicaid Prescription Drug and Rebate Program provisions including drastic cuts to pharmacy reimbursement. In order to be compliant with the ACA and associated federal regulations, states are adopting and implementing the new, more stable, ACA FULs as a part of their reimbursement methodologies. A total repeal of the ACA Medicaid pharmacy reimbursement provisions would not only thwart efforts to reduce fluctuations in Average Manufacturer Price (AMP)-based FULS but also would thwart efforts to ensure comprehensive reimbursement that reflects the true cost for pharmacies to acquire and dispense drugs in the Medicaid program.

Pharmacy Quality Alliance (PQA) Members Endorse Two New Performance Measures:  The measures focus on Concurrent Use of Opioids and Benzodiazepines and Adherence to Non-Infused Disease Modifying Agents Used to Treat Multiple Sclerosis.  PQA focuses on improving the quality of medication management and use across healthcare settings with the goal of improving patients health.  PQA measures are used in a variety of ways, including in the Medicare Part D program.  Here are more details regarding the new measures: 

  1. Concurrent Use of Opioids and Benzodiazepines (COB): the percentage of individuals 18 years and older with concurrent use of prescription opioids and benzodiazepines
  2. Adherence to Non-Infused Disease Modifying Agents Used to Treat Multiple Sclerosis (PDC-MS): the percentage of individuals 18 years and older who met the Proportion of Days Covered (PDC) threshold of 80% during the measurement period for disease-modifying agents treating multiple sclerosis.

 In the States:

Ohio: NCPA submitted comments to the Ohio Department of Medicaid on proposed changes regarding the reimbursement of pharmacy services. NCPA generally supported the use of tiered professional dispensing fees based on volume of prescriptions filled, and the use of NADAC for reimbursement claims. NCPA opposed a proposed penalty of a slashed dispensing fee for those pharmacies that did not complete the cost of dispense survey. NCPA appreciates the collaboration with the Ohio Pharmacists Association and looks forward to continuing our work together in the state.