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 March 17, CMS announced an opportunity for the public to comment on the agency’s initial guidance for the Medicare Drug Price Negotiation Program, as required by the Inflation Reduction Act. Given the anticipated impact of the Drug Price Negotiation program on the practice of managed care pharmacy in the United States, AMCP took the opportunity to submit comments on several provisions outlined in CMS’ guidance. AMCP’s comments cover subject areas such as access to the Maximum Fair Price, manufacturer-specific data required for negotiation, evidence about therapeutic alternatives for the selected drug, CMS’ methodology for developing an initial offer, the removal of a drug from the selected drug list, and Part D formulary inclusion of the selected drug.
On March 31, AMCP submitted comments following a Feb. 2 proposed rule by the Internal Revenue Service, Employee Benefits Security Administration, and CMS regarding coverage of certain preventive services under the Affordable Care Act (ACA). In the comment letter, AMCP expresses support for the Departments' goals to increase access to preventive services.
On March 31, AMCP joined 10 other pharmacy organizations in a joint letter to Anne Milgram, Director of the U.S. Drug Enforcement Agency (DEA). The joint letter requests that the DEA extend flexibilities for telehealth prescribing of buprenorphine using the opioids-related public health emergency.
On March 10, AMCP submitted comments to CMS regarding a Notice of Proposed Rulemaking (NPRM) on Advancing Interoperability and Improving Prior Authorization Processes for Medicare Advantage Organizations, Medicaid Managed Care Plans, State Medicaid Agencies, Children’s Health Insurance Program (CHIP) Agencies and CHIP Managed Care Entities, Issuers of Qualified Health Plans on the Federally-Facilitated Exchanges, Merit-Based Incentive Payment System (MIPS) Eligible Clinicians, and Eligible Hospitals and Critical Access Hospitals. AMCP's comments address whether CMS should consider policies to require payers to include information about prior authorizations for drugs on the Patient Access API, the Provider Access API, and the Payer-to-Payer API and how information on the APIs might interact with existing prior authorization requirements.
On March 6, AMCP submitted a comment letter in response to the Centers for Medicare and Medicaid Services' Advance Notice of Methodological Changes for Calendar Year (CY) 2024 for Medicare Advantage (MA) Capitation Rates and Part C and Part D Payment Policies. AMCP's comments support CMS' proposed Universal Foundation and commitment to advancing health equity, as well as the use of inclusive and gender-affirming approaches to HEDIS measures.
On March 3, AMCP joined 11 other pharmacy associations in a sign-on letter addressing pharmacy priorities following the end of the COVID-19 Public Health Emergency (PHE) in May. The letter, addressed to HHS Secretary Xavier Becerra and White House COVID-19 Response Coordinator Dr. Ashish Jha, requests the Administration take immediate action to ensure continued access to certain critical patient care services delivered by pharmacists under the COVID-19 PHE.
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.
