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) 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.
The language in S. 1913 now included as part of S. 524 strikes the appropriate balance of prospectively identifying at-risk beneficiaries and help them obtain the necessary treatment sooner to address addictions potential abuse while simultaneously preserving a beneficiaries’ rights to be notified, submit their preferences for prescriber and pharmacy, and exercise appeals.
On March 8, 2016, the Centers for Medicare and Medicaid Services (CMS) released a proposed rule titled “Medicare Program; Part B Drug Payment Model1” under the authority of section 1115A of the Social Security Act and the Centers for Medicare and Medicaid Innovation (CMMI).
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) 2017 for Medicare Advantage (MA) Capitation Rates, Part C and Part D Payment Policies and 2017 Call Letter” released on February 19, 2016.
The Academy of Managed Care Pharmacy (AMCP) appreciates the opportunity to submit comments for the record on the hearing titled “Examining the Opioid Epidemic: Challenges and Opportunities” scheduled for February 23, 2016. AMCP supports a holistic, comprehensive, and multi-stakeholder approach among health care providers and patients that truly addresses the opioid epidemic.
The Academy of Managed Care Pharmacy (AMCP) appreciates the opportunity to submit comments for the record on the hearing titled “Examining Implementation of the Biologics Price Competition and Innovation Act” scheduled for February 4, 2016.
The Academy of Managed Care Pharmacy (AMCP) commends the Obama Administration and the Centers for Medicare and Medicaid Services (CMS) for its support of Senator Pat Toomey’s (R-PA) leadership in addressing the opioid epidemic and S. 1913 - “The Stopping Medication Abuse and Protecting Seniors Act.”
