Controlling
Prescription Drug Spending:
Cutting Pharmacy Reimbursement is Not
the Answer
What's wrong with cutting reimbursement to long-term
care pharmacies?
Pharmacies do not control the prices set by drug manufacturers
and wholesalers, nor do pharmacies have much control
over the prescriptions written by physicians, so cutting
reimbursement to pharmacies will have little impact
on total prescription drug spending. It's akin to a
physician treating a symptom without addressing the
underlying condition.
The numbers make this very clear. Despite the fact
that state Medicaid programs have not been increased
pharmacy reimbursement rates in years, total Medicaid
prescription drug spending has grown at an average annual
rate of 18.1 percent between 1997 and 2000, over two
times the annual growth rate in overall Medicaid spending.
Cutting payments to long-term care (LTC) pharmacies
is especially short-sighted and will force LTC pharmacies
to cut special services that they provide to the vulnerable
patients they serve.
Aren't state governments overpaying long-term care
pharmacies?
The report issued in 2001 by the Office of Inspector
General (OIG) at the U.S. Department of Health and Human
Services is incomplete, and states should not rely on
its findings in setting pharmacy reimbursement rates.
While the report suggests that Medicaid programs pay
pharmacies more than their costs of acquiring brand-name
drugs, the OIG admits that its sole area of study was
ingredient costs and that it gave no consideration to
other component costs "such as
the cost
to provide professional services other than dispensing
a prescription for instances such as therapeutic intervention,
patient education, and physician consultation; and the
cost of dispensing which includes costs for computers,
multi-part labels, containers, technical staff, transaction
fees, Medicaid-specific administrative costs, and general
overhead."
The OIG also made no attempt to study the adequacy
-- or, more accurately, the inadequacy -- of Medicaid
dispensing fees as reimbursement for the costs of pharmacy
services.
Aren't long-term care pharmacies reimbursed for
the services they provide?
Right now, most of the reimbursement for the dispensing,
delivery, and other special services provided by LTC
pharmacies is implicit - that is to say, LTC pharmacies
find their "reimbursement" in the spread between
the prices at which they purchase a drug and the average
wholesale price (AWP) of the drug as reported by the
drug's wholesaler or manufacturer.
While state Medicaid programs do pay a "dispensing
fee" to pharmacies, even the most generous fee
falls well short of the costs of dispensing by LTC pharmacies.
The spread between the pharmacy reimbursement rate and
pharmacies' acquisition costs has traditionally permitted
LTC pharmacists to make a small profit, despite the
inadequacy of state dispensing fees.
As a result, states cannot cut their pharmacy reimbursement
rates, and cut dispensing fees or hold them at their
current levels, and expect that LTC pharmacies will
be able to continuing providing their special services
to nursing home patients and other patients with special
needs.
What's the solution?
Cutting reimbursement to LTC pharmacies for drugs is
not the answer. The professional services that LTC pharmacies
provide to the nation's frail elderly ensure that their
health care is both of high quality and cost-effective,
and government health plans should reimburse pharmacies
-- one way or another -- for these valuable services.
If states shouldn't cut pharmacy reimbursement,
what can they do to control prescription drug spending?
States have a number of options beyond simply cutting
pharmacy reimbursement rates, and a number of states
have employed these options successfully. Many of these
options are not appropriate for the frail elderly, however,
so states should strongly consider applying these policies
only to relatively healthy and ambulatory seniors.
States are permitted to adopt formularies - lists of
covered drugs - and exclude from these lists any drugs
that do not have significant therapeutic advantages
over other drugs covered under the formulary for a particular
disease or condition. Physicians may still prescribe
drugs which are not on the formularies, but they must
first seek prior authorization from the Medicaid agency.
In addition, a number of states are considering preferred
drug lists, which seek to save money by influencing
physicians to prescribe less expensive drugs that provide
similar therapeutic results. Drugs not listed require
prior approval from a pharmacist working for the state.
Florida estimates that the first year's savings from
the preferred drug list will be at least $100 million,
in part from supplemental rebates paid by manufacturers
that wish to ensure spots on the list for their drugs.
Generic substitution policies, which require pharmacies
to dispense a generic drug instead of a prescribed brand-name
drug when a generic equivalent is available, are in
place in at least 16 states. States without these policies
have the flexibility under Medicaid to encourage the
use of generics through differential dispensing fees,
differential payment rates, and other similar means.
States also have broad flexibility to employ utilization
management tools, such as prior authorization, drug
utilization review systems, and "fail first"
controls, which require physicians to show that alternative
therapies are ineffective before prescribing newer and
more costly drugs.
States have a variety of tools at their disposal for
controlling prescription drug spending, and employing
these tools makes much more sense that cutting reimbursement
rates to pharmacies that neither set drug prices nor
write drug prescriptions.
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