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The Voice of Debra Devereaux
At the beginning, it all sounds great…the PowerPoint presentation was informative, and the staff who came to present all seemed very competent and caring with a lot of integrity. Then the negotiations begin, and there’s a lot of back and forth and he-said/she-said, and you give up. That is not a great strategy for getting a Pharmacy Benefit Manager (PBM) contract that meets your financial, compliance, and Star Ratings goals. You must have a letter of agreement if you are implementing a new plan, but the contract negotiation may stretch into the latter part of third or fourth quarter. You are better off taking your time, getting your own legal counsel review, and staying true to your plan goals.
Top of mind when we are talking about Medicare compliance should be that the ultimate customer is the taxpayer who funds this program. That’s why the Centers for Medicare & Medicaid Services (CMS) has to attempt to account for every nickel that comes into or goes out of the programs. One of the murkiest finance areas is in Medicare Part D – that is Direct and Indirect Remuneration (DIR). CMS published a memo on January 19, 2017, with this very title.¹ DIR is the additional compensation – besides a partially capitated payment from CMS – received by a plan sponsor or Pharmacy Benefit Manager (PBM) after the pharmacy point of sale (POS) transaction. This changes the final cost of the drug for the plan sponsor or the price of the drug paid to the pharmacy. DIR has grown significantly in the past few years in large part because of the growth of preferred network pharmacies. CMS states they have observed “a growing disparity between gross Part D drug costs, calculated based on costs of drugs at the POS, and net Part D drug costs, which account for all DIR.”
“There’s no harm in hoping for the best as long as you’re prepared for the worst.”—Stephen King
It’s the formulary season, and you should be in the home stretch for your Health Plan Management System (HPMS) submission. What’s on the formulary and what changes were made to the formulary are among the top reasons why members either enroll in or disenroll from a health plan. Manufacturer price increases over the past two years and the number of high-cost specialty drugs released to market make formulary decisions and utilization increasingly difficult and significant to the health plan’s bottom line. With an average generic medication utilization rate of 80-85%, there is limited movement to improve. Some thoughts to consider:
There continues to be a lot of buzz about value-based insurance design (VBID). VBID is the idea that consumers’ out-of-pocket medical costs should be based on the value of a service to their health and not the price. Health Affairs defined VBID as “an approach that attempts to improve the quality of care by selectively encouraging or discouraging the use of specific healthcare services, based on their potential benefit to patients’ health, relative to their cost.”
The United States Senate conducted the first day of hearings Wednesday, December 9, on the high price of pharmaceuticals. The Special Committee on Aging is investigating the soaring prices of old drugs, including the overnight price hike of Turing’s Daraprim from $18 to $750. Every day there is another press release about the egregious increase in pricing of a generic drug or a newly-released-to-market medication. U.S. drug prices are the highest of any in the industrialized world.