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.
On Dec. 27, the Centers for Medicare and Medicaid Services (CMS) unveiled a Notice of Proposed Rulemaking (NPRM) on improvements to the Medicare Advantage and prescription drug programs. In a Feb. 13 comment letter, AMCP offers suggestions for strengthening CMS' Medication Therapy Management program, accessible format requirements, and approved formulary, as well as proposals to increase health equity in Medicare Advantage.
On Dec. 2, the Centers for Medicare and Medicaid Services (CMS) issued a Request for Information (RFI) on Essential Health Benefits (EHB). The RFI sought input on a proposed switch to the U.S. Pharmacopeia Drug Classification (USP DC) standard for defining the EHB prescription drug category. AMCP's comments, submitted on Jan. 31, urge CMS to refrain from switching to any alternative prescription drug classification standard.
On Dec. 21, the Department of Health and Human Services released a proposed rule titled "Patient Protection and Affordable Care Act, HHS Notice of Benefit and Payment Parameters for 2024." On Jan. 30, AMCP submitted comments which oppose two issues from the proposed rule; continuing formulary tier limitations for standardized plan options and new limits on the number of non-standardized plan options that issues may offer through the federal Marketplace.
On Jan. 27, AMCP, along with 76 other healthcare organizations, signed on to a consensus statement on health equity. In the statement, signatories recognize health inequity as a complex issue and reaffirm their commitment to take action within their organizations to reduce health inequities for the broader population.
On Dec. 15, AMCP joined 29 other pharmacy organizations in a letter calling on the Centers for Medicare and Medicaid Services to build upon the Public Readiness and Emergency Preparedness Act with guidance clarifying that states should reimburse clinical services provided by pharmacists at the same rates as other non-physician providers.
The Centers for Medicare and Medicaid Services (CMS) unveiled a Request for Information (RFI) titled "Make Your Voice Heard" on September 6. The RFI sought public input on healthcare accessibility, understanding provider experiences, advancing health equity, and assessing the impact of waivers and flexibilities provided in response to the COVID-19 Public Health Emergency. On November 4, AMCP responded with a comment letter offering insights into challenges related to access to medication. The comments also offer recommendations for advancing health equity within CMS.
Given the current complexities of the Medicaid, Children's Health Insurance Program (CHIP), and Basic Health Program enrollment processes, AMCP submitted comments in response to a September 7 Notice of Proposed Rulemaking (NPRM) from the Centers for Medicare and Medicaid Services (CMS). Dated November 4, AMCP's comments support the NPRM's proposed goal to simplify the enrollment process for these vital health programs. The comments specifically address the cycle of enrollment and disenrollment that program beneficiaries face, often referred to as “eligibility churn."
On August 4, the Department of Health and Human Services released a Notice of Proposed Rulemaking on Nondiscrimination in Health Programs and Activities. In response, AMCP submitted comments on September 29 which applaud the Department's goal to reinstate regulatory protections from discrimination in covered health programs and activities.
On August 30, AMCP provided comments to the Centers for Medicare and Medicaid Services (CMS) following the agency's request for feedback on ways to strengthen the Medicare Advantage program.
On August 19, AMCP joined a wide coalition of pharmacy organizations in calling on the Department of Health and Human Services to issue a PREP Act declaration that pharmacists, pharmacy students, and pharmacy technicians, as appropriate, can order and administer FDA authorized or approved monkeypox vaccines, testing, and therapeutics.
On June 9, AMCP submitted comments to CMS on the 2022 Healthcare Common Procedure Coding System (HCPCS) Public Meeting. AMCP applauds CMS's efforts to standardize coding and billing practices for prescription digital therapeutics (PDTs), and recommends that CMS create additional codes to cover the full range of PDTs.
On June 7, AMCP joined a pharmacy stakeholder letter to the Department of Health and Human Services (HHS) requesting clarification that pharmacies will maintain personnel flexibilities granted under the PREP Act emergency declaration through October 1, 2024.
