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 supports a coalition of over 20 health care stakeholders committed to aligning 42 CFR Part 2 (Part 2) with HIPAA to allow appropriate access to patient information that is essential for providing whole-person care.
The Academy of Managed Care Pharmacy (AMCP) supports the passage of Assembly Bill 3982 mandating that practitioners issue prescriptions for controlled substances electronically using an electronic health records system. E-prescribing for controlled substances would reduce some prescription errors and help prevent more than 2 million adverse drug events per year, 130,000 of which are life threatening. AMCP members seek to reduce the public health crises associated with medication prescribing errors, abuse and diversion of opioids, all of which AB 3982 addresses.
The Academy of Managed Care Pharmacy (AMCP) appreciates the opportunity to submit comments for the record on the hearing titled “Examining the Proposed Medicare Part B Drug Demonstration” held on June 28, 2016. AMCP submitted detailed comments1 to the Centers for Medicare and Medicaid Services (CMS) in response to the proposed rule titled “Medicare Program; Part B Drug Payment Model (CMS-1670-P)” published in the Federal Register on March 11, 2016.
The Department of Health and Human Services (HHS) and the Substance Abuse and Mental Health Services Administration (SAMHSA) released a final rule titled “Medication Assisted Treatment for Opioid Use Disorders” scheduled to be published in the Federal Register on July 8, 2016. AMCP had submitted comments on the draft rule urging for provisions related to team-based care, education on diversion mitigation strategies, and the expansion of practitioner eligibility to prescribe buprenorphine for opioid abuse disorders.
The Academy of Managed Care Pharmacy (AMCP) thanks the Centers for Medicare and Medicaid Services (CMS) for the opportunity to provide comments in support of the notice titled “Medicare Part D Reporting Requirements and Supporting Regulations (CMS-10185)” published in the Federal Register on May 6, 2016. Under the notice, Part D sponsors would be responsible for submitting Medication Therapy Management (MTM) program reports as described in Title I, Part 423, Subpart D, § 423.153 for CY2017 by the last Monday of February in 2018.
The Academy of Managed Care Pharmacy (AMCP) supports Senate Bill 2313 –establishing a task force to study and analyze health insurance payer practices regarding the dispensing of specialty drugs directly to a patient or provider. AMCP recommends that the Committee add language including a managed care pharmacist as a member on the task force.
The undersigned pharmacy organizations would like to thank the Centers for Medicare and Medicaid Services (“CMS”) for the opportunity to comment on the Proposed Rule for the Medicare Program; Merit-Based Incentive Payment System and Alternative Payment Model Incentive under the Physician Fee Schedule (“PFS”), and Criteria for Physician-Focused Payment Models (the “Proposed Rule”).
The Academy of Managed Care Pharmacy (AMCP) supports the passage of Senate Bill 1024. This bill would remove the December 31, 2016 sunset date currently in force which allows health care payment or benefit provider’s access to the state electronic system for monitoring schedules 2-5 controlled substances.
On June 15, 2016, the Medicare Payment Advisory Commission (MedPAC)1 released its June 2016 Report to the Congress: Medicare and the Health Care Delivery System2. Of the 347-page report, three chapters focus on examining policy issues related to prescription drugs, with a particular focus around “rapid growth in drug prices, which can affect beneficiary access to needed medications, as well as the financial sustainability of the Medicare program.”
The Academy of Managed Care Pharmacy (AMCP) is writing to express our opposition to certain mandated provisions in S. 3419 – C, an act establishing and mandating requirements for step therapy programs used by insurers, et al. This legislation as proposed would impose unnecessary additional requirements for an insurer’s step therapy program.
The Academy of Managed Care Pharmacy (AMCP) acknowledges that abuse deterrent opioid analgesic drug products are appropriately prescribed for certain patients, but should not be required by state mandates. For this reason, AMCP opposes House Bill 1048 because it implements a state mandate requiring the use of the abuse deterrent products that may not be necessary for every patient.
The Academy of Managed Care Pharmacy (AMCP) thanks the Agency for Healthcare Research and Quality (AHRQ) for its work in developing strategies to address the growing opioid epidemic in the United States and for the opportunity to provide comments in response to the draft technical brief titled “Medication-Assisted Treatment (MAT) Models of Care for Opioid Use Disorder in Primary Care Settings.”
