On November 14th the Montana Pharmacy Association (MPA) was at the ARM Hearing in Helena to explain to Montana Medicaid the importance of special packaging and current compounding regulations.
The ARM amendment 37.86.1101 and 37.86.1105 pertains to Medicaid reimbursement for dispensing fees and outpatient, compound prescriptions. The pharmacy dispensing fee is based on the pharmacy’s average cost of filling prescriptions and whether the pharmacy dispenses a generic, preferred drug list or non-preferred drug. The average cost of filling a prescription will be based on the direct and indirect costs that can be allocated to the cost of the prescription department and that of filling a prescription, as determined from the Montana Dispensing Fee Questionnaire. The average statewide dispensing fee is estimated to be $8.75 for preferred drug list medications. You may call Montana Medicaid to see where your pharmacy dispensing fee falls between $6.16 to a maximum of $10 for brand and generic preferred drug list medications. A dispensing fee of $5.50 will be given for all non-preferred drug list medications.
Unfortunately, the unit dosing fee of $0.75 per prescription will no longer be in effect after January 1st, 2008 when all this kicks in. CMS had tied the cost of unit dosing (special packaging), overhead costs, prescription volume, and personnel wages all into the dispensing fee. Since CMS will not allow for additional unit dosing fees, MPA suggested to give an additional 1$ dispensing fee for each medication to pharmacies who special package medications due to the additional costs of materials, extra “man” hours, delivering of the packages, etc.
In addition, any new store would only be assigned a 6 month interim dispensing fee of $5.50. MPA suggested that the new store be assigned the average fee of $8.75 since the new stores have not built up volumes and costs would be high.
Montana Medicaid’s proposed rule on compounding consists of using line item billing only (no more 00888 codes), and the use of compounding dispensing fees based on level of effort: $12.50, $17.50, $22.50. Any prescription over the level of effort of $12.50 dispensing fee would require a call the to the Prior Authorization unit to receive one of the higher dispensing fees. Another issue is that Medicaid had stated in the hearing notice that “the department encourages providers to explore rebatable or less costly excipients,” this would require extra inventory of rebate able products, and from what was explained by compounding pharmacists, PCCA has no or very few rebate able products and requires their new pharmacies to use their products, exclusively. In addition, reimbursement for mainly the rebate able ingredient still does not account for all the overhead costs associated with compounding. All three compounding pharmacists who spoke, said at these reimbursement rates, they would not be able to serve the Medicaid population. MPA’s position is to have no change in the current compounding program and to continue to use usual and customary fee, especially since compounding prescriptions is less than 1% of the Medicaid budget. Please visit GrizRPh.com or RxMT.org for further information.
Wednesday, November 21, 2007
Sunday, November 11, 2007
H.R. 971 and S.2161...Hand in Hand through Anti-trust Law.
S.2161 was introduced into the Senate by Senator Johnny Isakson [GA] (introduced 10/15/2007). Bill Text here. This is a companion bill to H.R. 971. These are bills to ensure and foster continued patient safety and quality of care by making the antitrust laws apply to negotiations between groups of independent pharmacies and health plans and health insurance issuers (including health plans under parts C and D of the Medicare Program) in the same manner as such laws apply to protected activities under the National Labor Relations Act.
In addition, The House Judiciary Committee passed HR 971 by a unanimous voice vote on Wednesday, Nov. 7. Read ACPCN ALERT here.
Also, H.R. 1474 "Fair and Speedy Treatment (FAST) of Medicare Prescription Drug Claims Act of 2007" Update: has a whopping 229 co-sponsors and is being referred to the Subcommittee on Health.
In addition, The House Judiciary Committee passed HR 971 by a unanimous voice vote on Wednesday, Nov. 7. Read ACPCN ALERT here.
Also, H.R. 1474 "Fair and Speedy Treatment (FAST) of Medicare Prescription Drug Claims Act of 2007" Update: has a whopping 229 co-sponsors and is being referred to the Subcommittee on Health.
Sunday, October 28, 2007
IMPORTANT NOTICE: Medicaid Reimbursement!!!
Representative Pallone has introduced a very important piece of legislation into the House of Representatives…H.R.3700.
H.R.3700, the `Fair Medicaid Drug Payment Act of 2007', is the bill we NEED to SAVE OUR HIDES before the implementation of the new AMP. H.R.3700 can be meshed easily with Baucus’s S.1951, also known as the `Fair Medicaid Drug Payment Act of 2007' in the Senate, and will keep our heads above water until we can tweak it later, and maybe implement some of H.R.3140 into it when time permits. Both S.1951 and H.R.3700 are easily implemented into Congress since they both deal with a 300 percent of the weighted average of the most recent average manufacturer prices for purchase by retail community pharmacies and we don’t need to bring out the calculator again and spend a bunch of time on calculations as we would with H.R.3140’s Retail Acquisition Costs.
So please…at this point in time support H.R.3700 and S.1951, the `Fair Medicaid Drug Payment Act of 2007' and please write to Congressman Rehberg thanking him for his previous support of pharmacy Medicare legislation H.R.971 and H.R.1474 and to PLEASE CO-SPONSOR H.R.3700.
S.1951 and H.R.3700 are our only hope at this point in time before Congress packs up and goes home to Save our Community Pharmacy Hides before the implementation of the devastating CMS proposed AMP, which is 36% below our acquisition cost according to the GAO studies. With this in mind, please don’t delay, call Congressman Rehberg at (406) 256-1019 or email him at http://www.house.gov/writerep/ or go to www.grizrph.com and click on REPRESENTATIVE CONTACTS for other numbers/ fax numbers/ emails, etc. Time is of the essence. For more information on this bill, CMS, AMP, GAO and other Medicaid/ Medicare bills, please visit Grizrph.com…In the Spotlight!
"Representative Pallone and Senator Baucus are in strong positions to move their respective legislation, get into a conference, and send a single bill to the President before they adjourn" states Executive Director of MPA Jim Smith.
In addition H.R.1474 (Medicare Prompt Payment Legislation) has House Majority of 223 of 435 members signed on as co-sponsors.
And please visit GrizRph.com, In the Spotlight, for the low-down on H.R.971 (Medicare Pharmacy Negotiation Bill)…it has gone to hearing and independent pharmacies got maximum results.
Please visit the Montana Pharmacy Association (MPA) website (www.rxmt.org) for important updates including letters to our Representative and Senators by MPA President Jim Seifert, a great article by Carla Cobb entitled “Pharmacists Aren’t Just Bottle Fillers”, Dean Forbes Newsletter, Update on Rosiglitazone concerns by Sherill Brown, and much more.
Thank you,
Eric Shields, Pharm.D.
H.R.3700, the `Fair Medicaid Drug Payment Act of 2007', is the bill we NEED to SAVE OUR HIDES before the implementation of the new AMP. H.R.3700 can be meshed easily with Baucus’s S.1951, also known as the `Fair Medicaid Drug Payment Act of 2007' in the Senate, and will keep our heads above water until we can tweak it later, and maybe implement some of H.R.3140 into it when time permits. Both S.1951 and H.R.3700 are easily implemented into Congress since they both deal with a 300 percent of the weighted average of the most recent average manufacturer prices for purchase by retail community pharmacies and we don’t need to bring out the calculator again and spend a bunch of time on calculations as we would with H.R.3140’s Retail Acquisition Costs.
So please…at this point in time support H.R.3700 and S.1951, the `Fair Medicaid Drug Payment Act of 2007' and please write to Congressman Rehberg thanking him for his previous support of pharmacy Medicare legislation H.R.971 and H.R.1474 and to PLEASE CO-SPONSOR H.R.3700.
S.1951 and H.R.3700 are our only hope at this point in time before Congress packs up and goes home to Save our Community Pharmacy Hides before the implementation of the devastating CMS proposed AMP, which is 36% below our acquisition cost according to the GAO studies. With this in mind, please don’t delay, call Congressman Rehberg at (406) 256-1019 or email him at http://www.house.gov/writerep/ or go to www.grizrph.com and click on REPRESENTATIVE CONTACTS for other numbers/ fax numbers/ emails, etc. Time is of the essence. For more information on this bill, CMS, AMP, GAO and other Medicaid/ Medicare bills, please visit Grizrph.com…In the Spotlight!
"Representative Pallone and Senator Baucus are in strong positions to move their respective legislation, get into a conference, and send a single bill to the President before they adjourn" states Executive Director of MPA Jim Smith.
In addition H.R.1474 (Medicare Prompt Payment Legislation) has House Majority of 223 of 435 members signed on as co-sponsors.
And please visit GrizRph.com, In the Spotlight, for the low-down on H.R.971 (Medicare Pharmacy Negotiation Bill)…it has gone to hearing and independent pharmacies got maximum results.
Please visit the Montana Pharmacy Association (MPA) website (www.rxmt.org) for important updates including letters to our Representative and Senators by MPA President Jim Seifert, a great article by Carla Cobb entitled “Pharmacists Aren’t Just Bottle Fillers”, Dean Forbes Newsletter, Update on Rosiglitazone concerns by Sherill Brown, and much more.
Thank you,
Eric Shields, Pharm.D.
Sunday, September 30, 2007
Recap on Current Legislation
Things are looking up in Montana. We are very fortunate to have such supporting representatives on pharmacy issues. Please thank Senator Tester for co-sponsoring S1951 and S1954. As of Monday Sept 24, 2007, Senator Tester co-sponsored Senatot Baucus’s pharmacy legislation S1954 ”Pharmacy Access improvement Act (PhAIM) of 2007” and S1951 “The Fair Medicaid Drug Payment Act”. You may view this legislation on GrizRph.com, In The Spotlight.
In addition, please call or e-mail Congressman Rehberg, to ask him to co-sponsor HR3140 “The Saving Our Community Pharmacies Act of 2007”. This is the final remaining piece of the pharmacy legislation puzzle. We can’t quit now with so much that we’ve gained. Rehberg’s office has already heard from all the usual pharmacists and individuals concerned about pharmacy legislation and are waiting to hear from more of those pharmacists and individuals deep in the trenches.
Let Congressman Rehberg know how devastating it would be to your pharmacy to be reimbursed on average 36% below acquisition cost for the medications you have spent time and money on filling, not to mention special packaging. Then please take it one step further and explain how this will affect your patients, whom you take so well care of, by either having to reject Medicaid patients or having to close your doors due to low reimbursement. Please, it just takes a few minutes…Contact Congressman Rehberg.
Read all about HR3140 at GrizRPh.com, In the Spotlight. In addition, please thank Congressman Rehberg for all his previous support of pharmacy by co-sponsoring all the other important pharmacy legislation in the House... such as HR1474 and HR971.
These are all very crucial pieces of pharmacy legislation and we should be very thankful to have such supporting representatives. If you haven’t done so, please call or e-mail their offices to thank them at www.grizrph.com/repcontact.htm.
LIST OF CURRENT FEDERAL PHARMACY LEGISLATION
As of 9/30/07
Sincerely,
Eric Shields, Pharm D
In addition, please call or e-mail Congressman Rehberg, to ask him to co-sponsor HR3140 “The Saving Our Community Pharmacies Act of 2007”. This is the final remaining piece of the pharmacy legislation puzzle. We can’t quit now with so much that we’ve gained. Rehberg’s office has already heard from all the usual pharmacists and individuals concerned about pharmacy legislation and are waiting to hear from more of those pharmacists and individuals deep in the trenches.
Let Congressman Rehberg know how devastating it would be to your pharmacy to be reimbursed on average 36% below acquisition cost for the medications you have spent time and money on filling, not to mention special packaging. Then please take it one step further and explain how this will affect your patients, whom you take so well care of, by either having to reject Medicaid patients or having to close your doors due to low reimbursement. Please, it just takes a few minutes…Contact Congressman Rehberg.
Read all about HR3140 at GrizRPh.com, In the Spotlight. In addition, please thank Congressman Rehberg for all his previous support of pharmacy by co-sponsoring all the other important pharmacy legislation in the House... such as HR1474 and HR971.
These are all very crucial pieces of pharmacy legislation and we should be very thankful to have such supporting representatives. If you haven’t done so, please call or e-mail their offices to thank them at www.grizrph.com/repcontact.htm.
LIST OF CURRENT FEDERAL PHARMACY LEGISLATION
As of 9/30/07
Sincerely,
Eric Shields, Pharm D
Thursday, August 16, 2007
Summaries for S.1951 and S.1954
Please visit In the Spotlight to read very clear and concise summaries on these two very vital bills, as well as other vital bills regarding CMS and AMP!
Special thanks to APhA, Thomas R. Clark, RPh, MHS Director of Policy & AdvocacyAmerican Society of Consultant Pharmacists, and Jim Smith, Executive Director of Montana Pharmacy Association for breaking these bills down and/or sharing them with us!
Special thanks to APhA, Thomas R. Clark, RPh, MHS Director of Policy & AdvocacyAmerican Society of Consultant Pharmacists, and Jim Smith, Executive Director of Montana Pharmacy Association for breaking these bills down and/or sharing them with us!
Sunday, August 12, 2007
Act Now..S.1954; S.1951 and H.R.1474 and H.R.1340
Finally…Hope, but a lot of work must be done before our goals of protecting pharmacy and preserving patient access to community pharmacies is accomplished.
Community pharmacies fill the void in health care by offering special services and medication packaging to further our health care system. Without our services and extra time providing theses services, many patients would be noncompliant and/or uneducated about the medication they or their loved one take; not to mention all pharmacists are the “first line against pharmaceutical and prescribing errors”. The list of services community pharmacies provide is numerous and is vital to our community, but unfortunately these services are being overlooked by our government wrapping all pharmacies into the same category with the mind set that all pharmacies, including PBM mail order pharmacies, have the same costs, services, and reimbursements. As we know this is clearly NOT TRUE!
Thanks to our very own Senator Baucus and Iowa’s Senator Grassley, they are putting their best foot forward by introducing the Pharmacy Access improvement Act (PhAIM) of 2007 (S.1954). This bill provides common sense fixes to the Medicare PartD program including 14 day electronic fund transfer for prompt reimbursement and paper claims within 30 days. Currently pharmacies are lucky to get paid by PBM’s in 30 to 60 days with the average pharmacy having to borrow $70,000 to hundreds of thousands of dollars just to make ends meet. In addition, PBM’s get paid monthly IN ADVANCE by Medicare, yet PBM’s “enjoy a considerable interest-earning float on tax-payers dollars intended to reimburse community pharmacies for serving their patients” said Roberts, RPh, of NCPA. During the year 2006, 1,152 community pharmacies were ‘shuttered or sold’ according to the NCPA-Pfizer Digest. The only thing new introduced into the pharmacy system was Medicare Part D, otherwise, community pharmacies would have continued their steady growth rate.
Similarly, H.R.1474 labeled the “Fair and Speed Treatment of Medicare Prescription Drug Claims” is making headway with a total of 190 bipartisan supporters. Please ask Congressman Rehberg to support H.R.1474 (GrizRPh News April 13th) as well as H.R.3140 (GrizRph News July 26th). Both these bills are similar to bills in the Senate, but we truly need to give every thing we’ve got to make this work since CMS has already made there statements to NOT CHANGE reimbursement which will be devastating to our pharmacies if these or similar bills do not pass. Rehberg’s staff is aware of these bills but they need to here from us…the pharmacists, technicians, and pharmacy owners in the trenches who see the devastating affects of Medicare and soon to be Medicaid on a daily basis with low and slow reimbursement. It just takes a few minutes to pick up the phone or email...yes, your opinion matters greatly!!! In numbers, we can stop these devastating affects to pharmacy!
In addition, Senator Baucus also introduced AMP fix legislation “The Fair Medicaid Drug Payment Act” (S.1951) which may save all our hides if implemented!!! Without this bill and other current pharmacy legislation, community pharmacies will be paid by Medicaid, on average, 36% below acquisition cost for medications, which will lead community pharmacies to eventually not participate by turning their backs on Medicaid patients, or close their doors. The Deficit Reduction Act of 2005 is suppose to decrease healthcare costs and national deficit not increase deficit and decrease patient healthcare, compliance, and pharmacy availability! Senator Baucus’s AMP fix focuses on a “300% reimbursement of AMP by COMMUNITY PHARMACIES on a nationwide basis and that FUL (Federal Upper Limits) do not vary monthly upon rebates, discounts or other pricing practices as well as the removal of mail order transactions from its calculations. Please support your pharmacy, and paycheck, by (1) thanking Senator Baucus for both S.1954 and S.1951. (2) Please also ask Senator Testor to Co-Sponsor S.1954 and other Senate pharmacy bills and (3) Please ask Congessman Rehberg to Co-Sponsor H.R.1474 (GrizRPh News April 13th) and H.R.3140 (GrizRPhNews July 26th). Please do your part and phone or email…we can protect pharmacy by standing up and shouting in one voice OR sit back and watch the devastating affects take place! Your choice will matter!!! Thank you for supporting Community Pharmacies as well as ALL PHARMACIES nationwide by writing to your Representatives! Please visit http://www.rxmt.org/ for a concise summary of these bills!
Thank you,
Eric Shields, PharmD
GrizRPh.com
Community pharmacies fill the void in health care by offering special services and medication packaging to further our health care system. Without our services and extra time providing theses services, many patients would be noncompliant and/or uneducated about the medication they or their loved one take; not to mention all pharmacists are the “first line against pharmaceutical and prescribing errors”. The list of services community pharmacies provide is numerous and is vital to our community, but unfortunately these services are being overlooked by our government wrapping all pharmacies into the same category with the mind set that all pharmacies, including PBM mail order pharmacies, have the same costs, services, and reimbursements. As we know this is clearly NOT TRUE!
Thanks to our very own Senator Baucus and Iowa’s Senator Grassley, they are putting their best foot forward by introducing the Pharmacy Access improvement Act (PhAIM) of 2007 (S.1954). This bill provides common sense fixes to the Medicare PartD program including 14 day electronic fund transfer for prompt reimbursement and paper claims within 30 days. Currently pharmacies are lucky to get paid by PBM’s in 30 to 60 days with the average pharmacy having to borrow $70,000 to hundreds of thousands of dollars just to make ends meet. In addition, PBM’s get paid monthly IN ADVANCE by Medicare, yet PBM’s “enjoy a considerable interest-earning float on tax-payers dollars intended to reimburse community pharmacies for serving their patients” said Roberts, RPh, of NCPA. During the year 2006, 1,152 community pharmacies were ‘shuttered or sold’ according to the NCPA-Pfizer Digest. The only thing new introduced into the pharmacy system was Medicare Part D, otherwise, community pharmacies would have continued their steady growth rate.
Similarly, H.R.1474 labeled the “Fair and Speed Treatment of Medicare Prescription Drug Claims” is making headway with a total of 190 bipartisan supporters. Please ask Congressman Rehberg to support H.R.1474 (GrizRPh News April 13th) as well as H.R.3140 (GrizRph News July 26th). Both these bills are similar to bills in the Senate, but we truly need to give every thing we’ve got to make this work since CMS has already made there statements to NOT CHANGE reimbursement which will be devastating to our pharmacies if these or similar bills do not pass. Rehberg’s staff is aware of these bills but they need to here from us…the pharmacists, technicians, and pharmacy owners in the trenches who see the devastating affects of Medicare and soon to be Medicaid on a daily basis with low and slow reimbursement. It just takes a few minutes to pick up the phone or email...yes, your opinion matters greatly!!! In numbers, we can stop these devastating affects to pharmacy!
In addition, Senator Baucus also introduced AMP fix legislation “The Fair Medicaid Drug Payment Act” (S.1951) which may save all our hides if implemented!!! Without this bill and other current pharmacy legislation, community pharmacies will be paid by Medicaid, on average, 36% below acquisition cost for medications, which will lead community pharmacies to eventually not participate by turning their backs on Medicaid patients, or close their doors. The Deficit Reduction Act of 2005 is suppose to decrease healthcare costs and national deficit not increase deficit and decrease patient healthcare, compliance, and pharmacy availability! Senator Baucus’s AMP fix focuses on a “300% reimbursement of AMP by COMMUNITY PHARMACIES on a nationwide basis and that FUL (Federal Upper Limits) do not vary monthly upon rebates, discounts or other pricing practices as well as the removal of mail order transactions from its calculations. Please support your pharmacy, and paycheck, by (1) thanking Senator Baucus for both S.1954 and S.1951. (2) Please also ask Senator Testor to Co-Sponsor S.1954 and other Senate pharmacy bills and (3) Please ask Congessman Rehberg to Co-Sponsor H.R.1474 (GrizRPh News April 13th) and H.R.3140 (GrizRPhNews July 26th). Please do your part and phone or email…we can protect pharmacy by standing up and shouting in one voice OR sit back and watch the devastating affects take place! Your choice will matter!!! Thank you for supporting Community Pharmacies as well as ALL PHARMACIES nationwide by writing to your Representatives! Please visit http://www.rxmt.org/ for a concise summary of these bills!
Thank you,
Eric Shields, PharmD
GrizRPh.com
Thursday, July 26, 2007
"A New Hope"
Please contact Congressman Rehberg and urge him to co-sponsor H.R. 3140.
In response to the Centers for Medicaid and Medicare Services (CMS) final ruling on Average Manufacturer Price (AMP), REPS. BOYDA, EMERSON AND 30 HOUSE MEMBERS INTRODUCE COMMON-SENSE FIXES TO MEDICAID PHARMACY REIMBURSEMENT RULE FOR GENERIC PRESCRIPTION DRUGS. See CMS final ruling posted on GrizRPh on July 11th, 2007.
H.R. 3140 “The Saving Our Community Pharmacies Act of 2007” rectifies the current pricing discrepancies and maintains patient- pharmacist relationship by:
• Redefining the pharmacy reimbursement benchmark to accurately reflect pharmacy acquisition costs. Retail Acquisition Cost (RAC) is the median price for each drug based on a quarterly survey of actual invoices subject to audit from a 5% representative sample of pharmacies nationwide. A FUL based on RAC will allow states to pay pharmacies accurately and preserve patient access.
• Excluding all sales to mail order facilities, as well as any pharmacy benefit manager (PBM) rebates and price concessions that are not available to retail pharmacies.
• Properly defining the retail class of trade to only include retail community pharmacies.
• Including provisions to drive generic utilization which would increase taxpayer and government savings.
Read the H.R. 3140 Fact Sheet provided by NCPA.
“The situation is serious, extremely serious,” said Bruce Roberts, RPh, NCPA executive vice president and CEO. “But it is not hopeless. It is not hopeless if we all take action in a well-planned, sustained effort. We’ve got about six months before the pain begins. Let’s use every day.”
Please visit the NCPA Website for more information on H.R. 3140.
Please contact Congressman Rehberg and urge him to co-sponsor H.R. 3140 through the GrizRPh.com Representative Contacts page. If we act now we may be able to prevent the Medicaid AMP Tragedy and save jobs and independent stores nationwide. Please do your part…this may be our last chance!
Thanks to NCPA and MPA for awareness on this issue!
Eric Shields, Pharm.D.
GrizRPh.com
In response to the Centers for Medicaid and Medicare Services (CMS) final ruling on Average Manufacturer Price (AMP), REPS. BOYDA, EMERSON AND 30 HOUSE MEMBERS INTRODUCE COMMON-SENSE FIXES TO MEDICAID PHARMACY REIMBURSEMENT RULE FOR GENERIC PRESCRIPTION DRUGS. See CMS final ruling posted on GrizRPh on July 11th, 2007.
H.R. 3140 “The Saving Our Community Pharmacies Act of 2007” rectifies the current pricing discrepancies and maintains patient- pharmacist relationship by:
• Redefining the pharmacy reimbursement benchmark to accurately reflect pharmacy acquisition costs. Retail Acquisition Cost (RAC) is the median price for each drug based on a quarterly survey of actual invoices subject to audit from a 5% representative sample of pharmacies nationwide. A FUL based on RAC will allow states to pay pharmacies accurately and preserve patient access.
• Excluding all sales to mail order facilities, as well as any pharmacy benefit manager (PBM) rebates and price concessions that are not available to retail pharmacies.
• Properly defining the retail class of trade to only include retail community pharmacies.
• Including provisions to drive generic utilization which would increase taxpayer and government savings.
Read the H.R. 3140 Fact Sheet provided by NCPA.
“The situation is serious, extremely serious,” said Bruce Roberts, RPh, NCPA executive vice president and CEO. “But it is not hopeless. It is not hopeless if we all take action in a well-planned, sustained effort. We’ve got about six months before the pain begins. Let’s use every day.”
Please visit the NCPA Website for more information on H.R. 3140.
Please contact Congressman Rehberg and urge him to co-sponsor H.R. 3140 through the GrizRPh.com Representative Contacts page. If we act now we may be able to prevent the Medicaid AMP Tragedy and save jobs and independent stores nationwide. Please do your part…this may be our last chance!
Thanks to NCPA and MPA for awareness on this issue!
Eric Shields, Pharm.D.
GrizRPh.com
Subscribe to:
Posts (Atom)