Letters, Statements & Analysis
AMCP communicates the importance of managed care pharmacy by collaborating with members to provide comments, analysis, and testimony to Congress and federal and state agencies on the impact of proposed regulations and laws on managed care pharmacy and patients.
As representatives of the drug supply and payment chain, ranging from pharmaceutical manufacturers, pharmacies, specialty pharmacies, managed care pharmacy, pharmacy benefit managers (PBMs), to health plans, we are aligned on the important principle that the private sector and state and federal governments must work together to facilitate Americans’ reliable access to needed prescription drugs during the COVID-19 pandemic.
Our organizations are pleased to submit these comments regarding the Food and Drug Administration’s (“FDA”) proposed rule regarding wholesale importation of prescription drugs from Canada. Collectively, we represent over 200,000 pharmacists, student pharmacists, residents and pharmacy technicians in all settings.
The Academy of Managed Care Pharmacy (AMCP) thanks the Centers for Medicare & Medicaid Services (CMS) for the opportunity to provide comments in response to its new Draft Guidance, “Advanced Notice of Methodological Changes for Calendar Year (CY) 2021 for Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies – Part II” published on February 5, 2020.
The Academy of Managed Care Pharmacy (AMCP) thanks the Centers for Medicare & Medicaid Services (CMS) for the opportunity to provide comments in response to its new Draft Guidance, “Patient Protection and Affordable Care Act; HHS Notice of Benefit and Payment Parameters for 2021; Notice Requirement for Non-Federal Governmental Plans” published in the Federal Register on February 6, 2020.
The Academy of Managed Care Pharmacy (AMCP) thanks the Food and Drug Administration (FDA) for the opportunity to provide comments in response to its new Draft Guidance, “Importation of Certain FDA-Approved Human Prescription Drugs, Including Biological Products, under Section 801(d)(1)(B) of the Federal Food, Drug, and Cosmetic Act [FDA-2019-D-5743]” published in the Federal Register on December 23, 2019.
On February 5, 2020, the Centers for Medicare & Medicaid Services (CMS) released the CY 2021 and 2022 Medicare Advantage and Medicare Prescription Drug Benefit Program Policy and Technical Rule, outlining proposed programmatic changes to the MA and Part D programs for two upcoming contract years. In a break from historic precedent, many of the program and policy changes that historically had been included in the Draft Call Letter were included in this proposed rule.
On February 5, 2020, the Centers for Medicare & Medicaid Services (CMS) released Part II of the Advance Notice of Methodological Changes for Calendar Year (CY) 2021 for Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies, outlining proposed payment changes and other requirements for plan sponsors participating in MA and the Part D program for the upcoming contract year.
The Academy of Managed Care Pharmacy (AMCP) thanks the Office of Inspector General (OIG) for the opportunity to provide written comments regarding the new proposed rulemaking on “Medicare and State Healthcare Programs: Fraud and Abuse; Revisions to Safe Harbors Under the Anti-Kickback Statute, and Civil Monetary Penalty Rules Regarding Beneficiary Inducements” published in the Federal Register on October 17, 2019.
In December 2016, AMCP applauded the passage of the 21st Century Cures Act as it included many provisions that will directly improve the health of Americans, from prompting new cures for cancer to combating opioid addiction.
AMCP expresses opinions on (SAMHSA’s) Confidentiality of Substance Use Disorder Patient Records Notice of Proposed Rulemaking (Proposed Rule).
The Academy of Managed Care Pharmacy (AMCP) thanks the Department of Health and Human Services (HHS) and the Centers for Medicare and Medicaid Services (CMS) for the opportunity to provide comments in response to the notice titled “Advance Summary of Methodological Changes for Calendar Year (CY) 2020 for Medicare Advantage (MA) Capitation Rates, Part C and Part D Payment Policies and 2020 Call Letter [CMS-2018-0154]” released on January 30, 2019.
The Academy of Managed Care Pharmacy (AMCP) thanks the Centers for Medicare and Medicaid Services (CMS) for the opportunity to provide comments in response to its proposed rule, “Medicare Program; Secure Electronic Prior Authorization for Medicare Part D [CMS-4819-P]” published in the Federal Register on June 19, 2019.
