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.
The Academy of Managed Care Pharmacy (AMCP) appreciates the opportunity to comment on Sub. H.B. No. 505 regarding the regulation of biological products and the substitution of interchangeable biological products when dispensed by pharmacists. AMCP is opposed to this legislation as it places an undue burden on the dispensing of interchangeable biological products once approved by the FDA.
The Academy of Managed Care Pharmacy (AMCP) supports the use of abuse deterrent opioid analgesic drug products; however, we are opposed to House Bill 2743 because it mandates coverage for these drug products, mandates preferred drug coverage status on formularies and sets arbitrary limits on copayments, deductibles or coinsurance that may result in increased costs to patients and public and private payers.
The Academy of Managed Care Pharmacy (AMCP) urges you to veto House Bill 1608 which would require the Insurance Commissioner to develop multiple prior authorization forms. For years, paper forms were used for prior authorization; however since 2013, an electronic standard for electronic prior authorization (ePA) has been available.
AMCP is writing to express our serious concerns regarding the inclusion of Section 11, Biological Product Innovation in the FDA and NIH Workforce Authorities Modernization Act (S. 2700)— part of the Senate Innovations legislation marked up in the HELP Committee.
The Academy of Managed Care Pharmacy (AMCP) believes that abuse-deterrent opioid analgesic drug products should be used in a clinically appropriate manner; however, we are opposed to Sub. H.B. No. 248 as it requires special consideration for this class of drugs.
The Academy of Managed Care Pharmacy (AMCP) appreciates the opportunity to submit comments for the record on the hearing titled “The Obama Administration’s Medicare Drug Experiment: The Patient and Doctor Perspective” scheduled for May 17, 2016.
The Academy of Managed Care Pharmacy (AMCP) thanks the Centers for Medicare and Medicaid Services (CMS) Center for Medicare and Medicaid Innovation (CMMI) for the opportunity to provide comments in response to the proposed rule titled “Medicare Program; Part B Drug Payment Model (CMS1670-P)” published in the Federal Register on March 11, 2016.
The Academy of Managed Care Pharmacy (AMCP) is writing to express its opposition to certain provisions of H.B. No. 254. AMCP opposes the practitioner notification requirements, which would place an unnecessary burden on the substitution of an interchangeable biological drug product. In addition, AMCP also opposes the new definition of “interchangeable biological product” included in the bill, which is not consistent with the Food and Drug Administration (FDA) definition.
The Academy of Managed Care Pharmacy (AMCP) is opposed to the prior authorization language under Article 25 – Health Care in Senate File No. 2356, the Senate Omnibus Supplemental Appropriations Bill because it restricts a health benefit plan’s ability to manage its formulary, and it establishes unreasonable standards for the use of prior authorization by health benefit plans. Instead, it replaces these managed care tools with a government mandated design.
The Academy of Managed Care Pharmacy (AMCP) is opposed to the prior authorization language under Article 25 – Health Care in Senate File No. 2356, the Senate Omnibus Supplemental Appropriations Bill because it restricts a health benefit plan’s ability to manage its formulary, and it establishes unreasonable standards for the use of prior authorization by health benefit plans. Instead, it replaces these managed care tools with a government mandated design.
The Academy of Managed Care Pharmacy (AMCP) is writing to express our concerns with Section 11 of S. 2700, the “FDA and NIH Workforce Authorities Modernization Act,” which was considered by the Senate Health, Education, Labor and Pensions Committee and placed on the Senate calendar on April 18th. This section of the bill states that “provisions of the Federal Food, Drug, and Cosmetic Act that refer to an official compendium as defined under section 201(j) of such Act shall not apply to a biological product subject to regulation under this section.”
The Academy of Managed Care Pharmacy (AMCP) thanks the Centers for Medicare and Medicaid Services (CMS) Center for Medicare and Medicaid Innovation (CMMI) for the opportunity to provide comments in response to the memorandum titled “Request for Public Comment on the Proposed Enhanced MTM Model Encounter Data Structure and Pilot Monitoring Measures” released on February 26, 2016.
