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.
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.
On April 27, AMCP joined a broad coalition of health care stakeholders in urging Congressional leaders to protect American's access to COVID-19 testing, treatments, and vaccines, regardless of insurance status - by replenishing the COVID-19 Uninsured Relief Fund.
On April 19, AMCP joined a pharmacy stakeholder letter addressed to the Biden administration's COVID-19 czar, Dr. Ashish Jha. The letter urged the Biden administration to allow qualified pharmacists to prescribe oral antivirals to treat COVID-19 and maintain PREP Act services provided by pharmacists.
On March 25, AMCP joined a diverse coalition of pharmacy stakeholders in expressing support for the Equitable Community Access for Pharmacists Services Act. This bill would permanently authorize pharmacists' ability to provide health care services during public health emergencies.
AMCP thanks the Senators and Congressmen on their leadership and introduction of the bipartisan, bicameral act.
On March 18, AMCP provided comments to the HHS Office of the National Coordinator for Health Information Technology regarding electronic prior authorization.
On March 9, AMCP joined 13 pharmacy organizations in urging President Biden to authorize pharmacists to order and administer oral antivirals to treat COVID-19 as part of the administration's Test to Treat policy.
