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.

AMCP Comments on Coverage of Preventive Services Under the ACA

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.
Legislation & Regulation

AMCP Comments on Proposed Rule Regarding Interoperability and Prior Authorization

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.
Legislation & Regulation

AMCP Submits Comments on CMS Advance Notice for 2024

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.
Legislation & Regulation

AMCP Joins Pharmacy Organizations in Letter on the COVID-19 PHE

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.
Legislation & Regulation

AMCP Comments on Proposed Rule to Strengthen Medicare Part C and Part D Programs

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.
Legislation & Regulation

AMCP Offers Comments on Essential Health Benefits

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.
Legislation & Regulation

AMCP Responds to Notice of Benefit and Payment Parameters for 2024

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.
Legislation & Regulation

AMCP Comments On Simplified Enrollment For Medicaid, CHIP, and Basic Health Programs

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."
Legislation & Regulation

AMCP Makes Its Voice Heard

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.
Legislation & Regulation