"Just tell us what you want us to do." That was the message I got a few years ago from an NCPA member from New Jersey – let's call him John. It was one of those so simple yet so impactful messages that I still remember where I was and the time of day when he said it to me.
The context for his statement was a fax alert NCPA had sent asking our members to contact their legislators and share pharmacy's perspective. In our message to members, we explained the "why" and the "how" and the "who" and eventually got to the "what" of our request. New Jersey John was polite but clear: One of our pharmacy partners had taken our fax and stripped the "how" and "why" from it and just left the "what." That stripped-down message is the one John had responded to. "All that other stuff is fine," New Jersey John said, "but what I want is for NCPA to tell me what you want me to do."
Message received. Loud and clear.
Fast forward to last Friday – the deadline for CMS' proposed drug pricing rule, which would ban retroactive pharmacy fees in Part D (aka pharmacy DIR as pharmacies have experienced them to-date). We asked pharmacies to weigh-in with CMS on the proposed rule. We reminded you frequently and often. As New Jersey John recommended, we told our members what you needed to do and boy, did you respond!
Nearly 3,500 comments were sent to CMS through the NCPA portal. The total number of replies to the proposed rule was 7,869. As a reminder, the proposed rule also contains controversial provisions that would reduce the number of protected drug classes and expand "step therapy" – both of which drew fire from pharmaceutical manufacturers, physicians, and patient groups and generated plenty of comments as well.
NCPA commented on those issues, too, in our formal response letter but, of course, it is the retroactive pharmacy payment reductions that were most squarely in our sights. With Part D retroactive pharmacy DIR being NCPA's top federal advocacy priority for many years, naturally we submitted 20+ pages of comments, providing evidence for converting this proposed rule into a final rule. We were also pleased to work with other pharmacy groups – including NACDS, NASP, and ASCP – to submit joint comments. More than 150 pharmacy groups signed a stakeholder letter – including a number of non-traditional pharmacy allies – supporting the proposed rule, too!
We also sent a joint comment letter with the American Society of Consultant Pharmacists and the Senior Care Pharmacy Coalition focusing on harm to seniors with proposed protected class changes, as well as on the need for a new definition of negotiated price and standardized pharmacy measures.
And naturally we worked to make sure the voice of CMS' most important constituent – the patient – was heard. We led in pulling together a support letter to CMS signed by more than two dozen patient advocacy groups. What's more, individual patients submitted 173 comments through NCPA's grassroots portal. Why wouldn't they? If finalized, the pharmacy DIR fixes could save the average patient nearly $200 per year or more on their out-of-pocket prescription drug costs.
Less uncertainty for pharmacies, lower costs for seniors – that's a no-brainer in our book. And as witnessed in comments to CMS, an overwhelming number agree.
So thank you New Jersey John for the good advice. NCPA told you what we wanted you to do. Wow, did you ever respond! Now we'll be working to encourage CMS to act on your input.
P.S. Just about the time I finished this column, we received word that CMS has released a long-awaited proposal that would eliminate the "safe harbor" for rebates between manufacturers and PBMs in Part D and Medicaid managed care. Our team is reviewing the proposed rule, and we'll have more to say about it next week. For now, here's a fact sheet from HHS on the proposal.
P.P.S. If you're considering registering for NCPA's 2019 Multiple Locations Conference – and I hope you are – you'd best get going. Preferred rates at the Wyndham Grand Clearwater Beach are only guaranteed through this Tuesday, Feb. 5. A great program awaits. Register now!