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 November 2, AMCP submitted comments on CMS’s Third Interim Final Rule responding to the COVID-19 emergency, thanking the agency for granting pharmacists the authority to order COVID-19 diagnostic tests for Medicare beneficiaries and expressing concern about the agency’s new guidance which would limit COVID-19 diagnostic tests without an order.
The efficient, well-coordinated distribution, allocation, and mass vaccination activities against the novel coronavirus (SARS-CoV-2) will help ensure vaccination is an effective countermeasure to the current pandemic.
On Oct. 5, AMCP submitted comments about the Part D MTM program, specifically in regards to the ability of plan sponsors and MTM vendors to provide annual CMR to individuals other than the beneficiary in certain circumstances in which the beneficiary is unable to participate.
On September 25, FDA issued a final rule related to the importation of prescription drugs from Canada.
Read AMCP's summary of the Medicare Coverage of Innovative Technology proposed rule that would provide a national coverage pathway for breakthrough devices, including digital therapeutics.
AMCP submitted comments in response to a request for information on how to improve the FDA Orange Book.
AMCP signed on to joint comments on the National Academies of Science, Engineering, and Medicine’s draft Preliminary Framework for COVID-19 Vaccine, advocating for the inclusion of pharmacists as front line health care workers.
AMCP submitted comments to the National Academies of Science, Engineering, and Medicine’s draft Preliminary Framework for COVID-19 Vaccine detailing our support to recognize pharmacists as front-line health care workers and pharmacies be included in the vaccine distribution and allocation plans.
AMCP sent a letter to HHS Secretary Azar detailing our concerns with the recent Executive Order that would make changes to the anti-kickback statute safe harbor for manufacturer rebates and the potential for increased costs for patients.
AMCP signed on to a joint letter with other Medicare program stakeholders to HHS Secretary Azar detailing concerns with a recent Executive Order that would make changes to the anti-kickback safe harbor for manufacturer rebates and increase costs for patients.
AMCP joined with other national pharmacy stakeholders to thank HHS Secretary Azar for the agency's authorization of pharmacist administration of children's vaccines.
On August 4, 2020, CMS issued a request for information on implementation of requirements for electronic prescribing of controlled substances in Medicare Part D. Please send any feedback to advocacy@amcp.org by September 25.
