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.

AMCP Submits Comments to the Alabama House Health Committee Expressing Concerns with Specific Provisions of House Bill 82 Regarding the Regulation of Biological Products and the Substitution of Interchangeable Biological Products

The Academy of Managed Care Pharmacy (AMCP) is writing to express concerns with specific provisions of House Bill 82 regarding the regulation of biological products and the substitution of interchangeable biological products when dispensed by pharmacists.

AMCP Submits Comments to the Alaska House Health & Social Services Committee Expressing Concerns with Specific Provisions of Senate Bill No. 32 Regarding the Regulation of Biological Products and the Substitution of Interchangeable Biological Products

The Academy of Managed Care Pharmacy (AMCP) is writing to express concerns with specific provisions of Senate Bill No. 32 regarding the regulation of biological products and the substitution of interchangeable biological products when dispensed by pharmacists.

AMCP Submits Comments to The Nebraska Senate Health and Human Services Committee Expressing Concerns with Specific Provisions of LB 481 Regarding the Regulation of Biological Products and the Substitution of Interchangeable Biological Products

The Academy of Managed Care Pharmacy (AMCP) is writing to express concerns with specific provisions of LB 481 regarding the regulation of biological products and the substitution of interchangeable biological products when dispensed by pharmacists.

The Partnership to Amend 42 CFR Part 2, a Coalition AMCP is Part of, Issues a Comment on the SAMHSA Final Rule and Urges Congress to Take the Next Steps in Modernizing 42 CFR Part 2

The Partnership to Amend 42 CFR Part 2, a coalition of nearly 30 health care organizations committed to aligning the Substance Abuse and Mental Health Service Administration's (SAMHSA) final rule on Confidentiality of Alcohol and Drug Abuse Patient Records, 42 Code of Federal Regulations Part 2 (Part 2) with the Health Insurance Portability and Accountability Act of 1996 (HIPAA) to allow appropriate access to patient information that is essential for providing whole-person care, issued the following statement in response to the Part 2 final rule.

AMCP Submits Comments to CMS on the Medicare Part D MTM Program Standardized Format Urging CMS to Work with the Pharmacy Profession to Modernize, Test, and Validate Alternate Formats to Maximize its Intended Benefit for Medicare Beneficiaries

The Academy of Managed Care Pharmacy (AMCP) thanks the Centers for Medicare and Medicaid Services (CMS) for the opportunity to provide comments on the notice titled “CMS-10396 Medication Therapy Management Program Improvements” published in the Federal Register on October 31, 2016. Under the notice, the Medicare Part D Medication Therapy Management (MTM) Program Standardized Format (“standardized format”) would be reauthorized in its current format for an additional three years through 2020.
Medicare Part D

AMCP Submits Comments on 21st Century Cures Act Supporting the Inclusion of ‘Section 3037 – Health Care Economic Information’ That Would Modernize FDAMA Section 114

The Academy of Managed Care Pharmacy (AMCP) appreciates the opportunity to submit comments for the record on the 21st Century Cures Act as revised in November 2016. AMCP supports the need for timelier and more proactive communications between biopharmaceutical manufacturers and population health decision makers.

AMCP Submits Comments in Response to PQA Endorsement Consideration of Two New Performance Measures: Concurrent Use of Opioids and Benzodiazepines and Adherence to Non-Infused Disease Modifying Agents Use to Treat Multiple Sclerosis

The Academy of Managed Care Pharmacy (AMCP) thanks the Pharmacy Quality Alliance (PQA) for the opportunity to provide comments in response to the Call for Comments on PQA Endorsement Consideration of Two New Performance Measures.
Patient Conditions/Disease States, Rare Diseases

AMCP Requests Meeting with the Office of Management and Budget to Discuss the Impact of the SAMSHA Pending Final Rule on Confidentiality of Substance Use Disorder Patient Records (42 CFR Part 2)

Consistent with established guidelines, we are writing to request a meeting with OMB/OIRA staff to discuss the impact of the final rule for SAMHSA- 4162-20: Confidentiality of Substance Use Disorder Patient Records. The modification of the federal regulations governing the confidentiality of drug and alcohol treatment and prevention records, 42 CFR Part 2 (Part 2), is a priority for the Academy of Managed Care Pharmacy (AMCP).

AMCP Submits Comments on USP’s Draft Medicare Model Guidelines v7.0

The Academy of Managed Care Pharmacy (AMCP) thanks the U.S. Pharmacopeial Convention (USP) for the opportunity to provide comments on the Draft Medicare Model Guidelines v7.0 as published on the USP website on October 1, 2016. AMCP and its members have been involved with the Medicare Model Guidelines since the inception of the process and appreciate USP’s willingness to receive input from the affected health care sectors.

AMCP Submits Comments to the Pennsylvania Senate Appropriations Committee Opposing House Bill 1698, Which Would Mandate Coverage for Abuse Deterrent Opioid Analgesic Drug Products

The Academy of Managed Care Pharmacy (AMCP) acknowledges that abuse deterrent opioid analgesic drug products are appropriate for certain patients. However, we are opposed to House Bill 1698 because it would mandate coverage for these products on every formulary, and restrict a health insurance plan’s ability to use utilization review requirements to determine the appropriate use of these products.