The Center for Medicare and Medicaid Services (“CMS”) is accepting public comment through Friday, March 7, 2014, on the 2015 Medicare Parts C and Part D Proposed Rule (the “Proposed Rule”). As you may know, APhA strongly supports many of the Proposed Rule’s provisions, particularly the expansion of Medication Therapy Management programs, new fulfillment and cost-sharing requirements for mail-order pharmacies, and the “any willing pharmacy” provision, which will open up preferred networks to new competition. APhA will submit extensive comments voicing our support for these provisions, but we also need your help!
These changes are the result of continuous advocacy efforts by APhA and other pharmacy organizations, and they are under attack by insurers and Pharmacy Benefit Managers. In fact, over 200 organizations signed a letter asking CMS to withdraw the Proposed Rule in its entirety. In order to ensure that these gains for pharmacy are not lost, it is essential that CMS hears your voice. Your comments on how the Proposed Rule will impact patient care based on your first-hand practical experience with MTM, preferred network exclusions and other topics addressed in the proposed rule, will be highly valuable to policymakers.
A sample letter expressing support for the MTM expansion is included in the link below. Please personalize your letter with your own experience—it is extremely important that you do not submit the letter “as is.” A form letter will do little to impact existing policy, but the voices of practicing pharmacists on the front lines of health care can make a powerful impression on policymakers.
If you have any questions, please contact Jillanne Schulte, Director of Regulatory Affairs, at email@example.com.
APhA is seeking your feedback on the CMS Part D proposed rule, released on January 10, 2014 (the “Proposed Rule”). The Proposed Rule includes a number of major changes to the Part D program. Below, we’ve highlighted major areas of concern and included very brief summaries of our proposed comments. Please note that the issue areas and summaries below are not exhaustive and represent only a portion of the issues on which we will be commenting. Our final comments will be substantially more detailed and inclusive—we’ve prepared these summaries simply for the purposes of gathering member input on the Proposed Rule. Each subject area includes a survey tool that allows you to send your feedback directly to us, so that we can fully incorporate it into our final comments, which are due March 7, 2014.
The changes laid out in the Proposed Rule have the potential to create major shifts in the Part D program. As such, the Proposed Rule is extremely controversial, with members of the health care community strongly divided on its provisions. Your input will be invaluable to us—it will strengthen and shape our comments so that we can offer the best possible response to CMS. We ask that you submit all feedback no later than February 26, 2014 to allow us time to synthesize your responses into our comments.
In March 2010, President Obama signed into law the Affordable Care Act (P.L. 111-148; ACA), also referred to as health care reform. Beyond provisions impacting patients and insurance companies, numerous provisions within the final law either impact directly or could impact pharmacists. ACA issues of importance to APhA, pharmacists, and the pharmacy profession include:
In 2012, FDA announced it is looking at ways to make the distinction between prescription and over-the-counter (OTC) drugs more flexible through "conditions of safe use" including interventions by a pharmacist or innovative technologies (OTC+).
APhA supports the concept and believes that this is an exciting opportunity for pharmacists to help improve public health, much like what pharmacists have done with immunizations.
The Centers for Medicare & Medicaid Services (CMS) established the Center for Program Integrity (CPI) to ensure the integrity of Medicare and Medicaid. Within CPI, the Division of Plan Oversight and Accountability (DPOA) safeguards Medicare Advantage (Part C) and Medicare Part D (Prescription Drug Program). DPOA carries out its mission with an experienced anti-fraud team, of which the Medicare Drug Integrity Contractors (MEDICs) are members. The MEDICs are comprised of the CMS National Benefit Integrity (NBI) MEDIC and the CMS Outreach and Education (O&E) MEDIC.