Fraud Waste and Abuse
Needle Exchange Programs Policy 9915 11/01/1999 Introduced 03/01/2004 Reapproved 12/01/2008 Reapproved 10/01/2012 Reapproved 02/08/2017 Reapproved | AMCP supports the use of needle exchange programs for substance abusers to reduce the risk of transmission of the human immunodeficiency virus (HIV), hepatitis B and C viruses, and other communicable diseases in intravenous drug users. |
Substance Abuse Programs
| AMCP supports the involvement of pharmacists in the development and promotion of programs that prevent substance abuse and educate about substance use disorder. AMCP recommends pharmacists monitor drug use to identify cases of misuse or abuse and work with providers and patients on the best evidence-based, therapeutic intervention and monitoring plan. |
Evidence-based Advertising of Pharmaceuticals
| 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. |
Pharmacist Recovery Programs Policy 0021 02/01/2000 Introduced 02/01/2003 Revised 02/01/2008 Revised 10/01/2012 Reapproved | AMCP supports the establishment by state boards of pharmacy of counseling, treatment, prevention, and rehabilitation programs for pharmacists, pharmacy technicians and student pharmacists who are subject to physical or mental impairment due to the influence of drugs – including alcohol – or other causes, when such impairment has potential to adversely impact their abilities to function properly in a professional capacity. AMCP supports the empowerment of state boards of pharmacy to use discretionary powers in determining employment waiver requests relating to the licensure of impaired pharmacists and pharmacy technicians.
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Therapeutic Purpose Inclusion on Prescriptions and Medication Orders Policy 0027 11/01/1999 Introduced | In order for pharmacists to fulfill their responsibility for monitoring and reviewing pharmaceutical care of the patient, AMCP encourages inclusion of the diagnosis and indication on prescriptions or medication orders to improve coordination of care and patient safety. |
Supply Chain Integrity (Title prior to 02/21/2021 revision: Pharmaceutical Counterfeiting) | AMCP encourages all entities involved in the pharmaceutical supply chain to assure that product integrity and stability is maintained throughout the continuum of the distribution system. AMCP supports the purchase and handling of products in ways that enhance the transparency and integrity of the product supply chain and encourages pharmacists to identify instances of product counterfeiting or adulteration. AMCP encourages efforts to provide consumers and health care professionals with information on how to avoid counterfeit or adulterated products and how to recognize, respond to, and report encounters with suspicious products.
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Drug Abuse/Illicit Drug Use
| AMCP supports legislation that balances the need for patient access to medications for legitimate medical purposes with the need to prevent diversion and illicit use. |
Fraud, Waste and Abuse in the Medicare Part D Prescription Drug Benefit Policy 1002 06/01/2010 Introduced 03/25/2019 Revised | AMCP is concerned about reports of fraud, waste and abuse within the prescription drug benefit. Fraud, waste and abuse are unacceptable within any health care system, and result in unnecessary payments and costs to patients and public and private payers. AMCP supports efforts that would reduce the instance of fraudulent activity, such as lifting the current “any willing provider” requirement and amending current law and allowing plans to suspend payments to pharmacies upon a credible allegation of fraud.
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Audits of Pharmacy Providers Policy 1103 12/01/2011 Introduced 10/01/2012 Reapproved | Audits serve two main purposes: 1) detecting fraud, waste and abuse, and 2) validating data entry and documentation to ensure they meet regulatory and contractual requirements. The audit process should be transparent and have a fair design and implementation. The managed care organization should supply the pharmacy provider with a document that defines the requirements on which it may base an audit. The actual audits should be conducted in a manner that leads to continuous quality improvement of the services of the provider, rather than as a source of revenue. Further, the provider must review and be comfortable with these documents before it agrees to a contract. It is imperative that pharmacists-in-charge, and their staff, understand the dispensing and billing requirements and the implications of non-compliance. A bilateral professional level of performance can make the audit process run smoothly, be educational and improve quality. (See AMCP Model Audit Guidelines for Pharmacy Claims) |
Fraud, Waste and Abuse in Prescription Drug Benefit
10/01/2011 Introduced | Fraud
Waste
Abuse
(See AMCP Managed Care Pharmacy Practice Positions - Fraud, Waste and Abuse in Prescription Drug Benefits) |
Management of Opioids
06/01/2013 Introduced | Prescription opioid medications can be effective for the treatment and management of severe acute pain; however, these medications are associated with serious risks to patients, including misuse, overdose, and death. To ensure the safe and appropriate use of opioid medications, the Academy of Managed Care Pharmacy (AMCP) supports policies that facilitate the ability of health plans and pharmacy benefit managers (PBMs) to effectively manage the use of opioids in their patient populations. Policies that address opioid use must strike an appropriate balance between the potential benefits and associated risks to patients. AMCP supports the ongoing development and use of prescription drug monitoring programs (PDMPs) and the expansion of PDMP access to include health plans and pharmacy benefit managers (PBMs). Allowing these organizations access to PDMPs will enhance their ability to recognize and assist patients who may be at risk for misuse or diversion of opioids and other controlled substances. AMCP supports mandatory electronic prescribing (e-prescribing) for opioids and other controlled substances as a means to reduce the potential for prescription forgery and errors and identify and minimize overprescribing. AMCP further advocates for sensible changes to existing federal and state laws to authorize implementation of safeguards, including Risk Evaluation and Mitigation Strategy (REMS) programs, education on overdose prevention and treatment, naloxone distribution programs, and programs that facilitate proper disposal of unused prescription medications.
006/01/2013 Introduced* 04/23/2018 Revised (*subject originally included policy on abuse deterrent and tamper resistant formulations, those subjects now included in Policy 1802) |
National Provider Number Policy 0015 02/01/2000 Introduced 02/01/2005 Revised 02/01/2010 Reapproved 03/25/2019 Revised | AMCP supports the use of the federally issued National Provider Identifier (NPI), a unique universal identifier number for each healthcare provider. AMCP also supports pharmacists’ use of an NPI to bill for clinical services. |
Therapeutic Purpose Inclusion on Prescriptions and Medication Orders
Policy 0027
11/01/1999 Introduced | In order for pharmacists to fulfill their responsibility for monitoring and reviewing pharmaceutical care of the patient, AMCP encourages inclusion of the diagnosis and indication on prescriptions or medication orders |
Disposal of Needles and Syringes Policy 0113 11/01/2001 Introduced 11/01/2005 Reapproved 11/01/2009 Reapproved 02/21/2018 Reapproved | AMCP supports the development and implementation of safe systems and procedures for the disposal of used needles and syringes by patients outside of health care facilities. |
Abuse Deterrent and Tamper Resistant Formulations
Policy 1802
04/23/2018 Introduced | AMCP encourages the U.S. Food and Drug Administration (FDA) to use its expertise to establish standards for the definition of “abuse-deterrent” and “tamper resistant.” The Agency should also require that manufacturers of those products undertake reasonable post-marketing surveillance studies that will help assess the impact of the products on both the abuse of the specific product, as well as overall rates of abuse. Because opioids may vary in their clinical effectiveness and abuse potential, AMCP supports expanding the ability of health plans to clinically manage these products. Therefore, AMCP does not support mandating the use of “abuse deterrent” and “tamper resistant products.” AMCP maintains that such products are not clinically necessary for all patients. |
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