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.
In a January 15th letter to President-elect Joseph R. Biden, AMCP shared its priority issues related to the COVID-19 pandemic and managed care pharmacy.
On Jan. 5, AMCP joined the Pharmacy Health Information Technology (PHIT) Collaborative and national pharmacy stakeholders in submitting comments to CMS on its Medicaid prior authorization proposed rule. AMCP supports expanding use of electronic prior authorizations, removing barriers to health information technology adoption and providing patients and providers with information regarding prior authorization decisions.
On Dec. 21, CMS published a Final Rule to support state flexibility to enter into value-based purchasing arrangements (VBPs) with drug manufacturers, and to allow manufacturers with qualifying VBPs to report multiple best price points for a single dosage form and strength of a covered outpatient drug. The final rule is effective on Jan. 1, 2022.
On Dec. 12, AMCP joined the Pharmacy Supply and Payment Chain Coalition's letter to Congressional leaders urging them to support the CDC's request for supplemental funding to cover the cost of administering COVID-19 vaccines.
On Nov. 30, AMCP submitted comments on CMS draft guidance for Calendar Year (CY) 2022 Medicare Advantage capitation rate and Part C and Part D payment policies. AMCP responded to CMS’s proposed introduction of a COVID-19 measure for the 2023 Part C and Part D performance measure display page and in the Star Ratings program, pending rulemaking.
On November 20, HHS released an Interim Final Rule with Comment Period (IFC) establishing a Most Favored Nation (MFN) Model for Medicare Part B drugs. The MFN Model will calculate the payment rate for included drugs based on a price that reflects the lowest per capita GDP-adjusted price among a group of OECD countries, with an additional flat payment based on the average payment for MFN Model drugs in 2019 adjusted quarterly for inflation.
On November 20, HHS released a Final Rule that amends the discount safe harbor regulation to eliminate protections for price concessions offered by pharmaceutical manufacturers to plan sponsors and pharmacy benefit managers (PBMs) under contract with plan sponsors starting January 1, 2022.
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.
On November 2, AMCP submitted comments on a CMS Medicare Coverage of Innovative Technology proposed rule establishing a national coverage pathway for innovative devices authorized under FDA’s Breakthrough Devices Program and clarifying the agency’s definition of “reasonable and necessary”. AMCP called on CMS to indicate how digital therapeutics (DTx) will fit into Medicare’s coverage and payment framework in its Final Rule.
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.
