Drug Pricing

Evidence-based Advertising of Pharmaceuticals

Policy 0012

02/01/2000 Introduced
02/01/2005 Revised
11/01/2009 Revised
12/01/2013 Revised

02/13/2019 Reapproved

02/21/2021 Revised

AMCP supports federal regulatory requirements that ensure that drug product advertising contains claims supported by evidence-based research, and that such advertising does not contribute to drug misuse or unwarranted healthcare expenditures.

AMCP believes that the best price provisions of the Medicaid prescription drug rebate program, established by the Omnibus Budget Reconciliation Act of 1990 (P.L. 101-508), represents interference by the government into the competitive marketplace that has raised costs unnecessarily by preventing the commercial market from allowing true market dynamics to emerge. This pernicious market effect has been well documented by the U.S. Government Accountability Office (GAO), the Congressional Budget Office (CBO) and academic economists.  AMCP strongly encourages a careful re-examination of the best price program.

(See AMCP Managed Care Pharmacy Practice Positions - Best Price Requirements of the Medicaid Drug Rebate Program)

Government Regulation of Prescription Drug Prices

Policy 1003

06/01/2010 Introduced

04/12/2021 Revised

AMCP believes that government regulation of prescription drug pricing could result in unintended consequences such as higher costs for patients, payers, and providers. Government-regulated prices could greatly impair the ability of managed care organizations (MCOs) to design a competitive benefit offering that integrates clinically sound, evidence-based medication choices with delivery systems and co-payment alternatives that provide beneficiaries with substantive choice. AMCP works to ensure patient access to medications at an affordable cost and supports working with elected officials and health care stakeholders to develop practical, informed, and market-based solutions to make prescription drugs more affordable and accessible.

(See AMCP Managed Care Pharmacy Practice Positions - Government Regulation of Prescription Drug Prices)

AMCP believes that government regulation of prescription drug pricing, regardless of its structure, would have an overall negative impact on consumer cost, quality, and access to health care benefits.  Legislation that allows the government to dictate reimbursement terms of a private contract between a payer and a pharmacy or that mandates that the payer disclose proprietary pricing methodology is not an appropriate focus of government regulation.  Further, AMCP believes that competitive negotiations between parties are more likely to provide fair and equitable reimbursement on drugs dispensed.  AMCP does not support the intervention of government into private contracts to require payers to advise pharmacies on where to purchase their drugs; that is an unnecessary and inappropriate intrusion into the private arrangements of a pharmacy with its supplier.  This type of government mandate takes away the incentive for a pharmacy to make wise purchasing decisions.  The payers and consumers will not benefit from a system of government mandated payments to a private entity; rather it will decrease competition and further drive up the cost of the prescription drug benefit.

 
[See AMCP Managed Care Pharmacy Practice Positions - Government Regulation of Prescription Drug Prices]

Transparency Within Health Care

Policy 1104

06/01/2011 Introduced

02/21/2021 Revised

Appropriate transparency throughout the health care delivery system can help all parties involved – including managed care organizations, pharmacy benefit managers, payers, providers, and patients – make informed decisions regarding the use of valuable health care resources. These decisions can help promote positive health outcomes protect patient safety and ensure the affordability of a prescription drug benefit. While certain information should remain confidential to ensure a competitive marketplace, AMCP supports efforts to promote transparency throughout the entire health care system.

(See AMCP Managed Care Pharmacy Practice Positions - Transparency Within Health Care)

Co-payment Offset Programs

Policy 1302

02/01/2013 Introduced

AMCP is supportive of programs that help patients afford their prescription drugs. However, some programs can needlessly encourage the use of more expensive brand-name products over their generic counterparts. They can also undermine the formulary development process by encouraging the use of products that have lower cost therapeutic alternatives. Patient safety can also be threatened when prescriptions are frequently transferred between retail pharmacies. Therefore, AMCP is opposed to manufacturer coupon programs that are promotional in nature and are not means-tested.

(See AMCP Managed Care Pharmacy Practice Positions - Co-Payment Offset Program)

The Competitive Model

Policy 1305

02/01/2013 Introduced

The Academy of Managed Care Pharmacy (AMCP) supports the continuation of the competitive model for the Medicare Part D program. The Academy supports legislation and regulation that will allow proven private sector best practices to be applied in the public sector.  The Academy will oppose changes to the drug benefit program that would undermine the use of effective managed care strategies.  It will oppose changes that would dilute the competitive structure currently being used for the delivery of the Medicare drug benefit. Additionally, program elements that hinder the use of pharmacy benefit best practices from the private sector should be eliminated.

(See AMCP Medicare Part D Concept Series – The Competitive Model)

Value Based Contracts

Policy 1801

04/23/2018 Introduced