On May 15, AMCP joined dozens of other health care organizations in a sign-on letter thanking the Biden Administration for relaunching the Cancer Moonshot program. First launched in 2016 with the mission to accelerate the rate of progress against cancer, the program's national goal is to reduce the death rate of cancer by at least 50% over the next 25 years. The letter applauds the program's prioritization of cancer prevention, especially though human papillomavirus (HPV) vaccination.
On April 27, AMCP submitted comments in response to the Office of Management and Budget's Initial Proposals for Updating Race and Ethnicity Standards. In the comment letter, AMCP provides several recommendations which align with the organization's strategic priority of Addressing Disparities in Medication Use and Access.
On March 17, CMS announced an opportunity for the public to comment on the agency’s initial guidance for the Medicare Drug Price Negotiation Program, as required by the Inflation Reduction Act. Given the anticipated impact of the Drug Price Negotiation program on the practice of managed care pharmacy in the United States, AMCP took the opportunity to submit comments on several provisions outlined in CMS’ guidance. AMCP’s comments cover subject areas such as access to the Maximum Fair Price, manufacturer-specific data required for negotiation, evidence about therapeutic alternatives for the selected drug, CMS’ methodology for developing an initial offer, the removal of a drug from the selected drug list, and Part D formulary inclusion of the selected drug.
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.
On March 31, AMCP joined 10 other pharmacy organizations in a joint letter to Anne Milgram, Director of the U.S. Drug Enforcement Agency (DEA). The joint letter requests that the DEA extend flexibilities for telehealth prescribing of buprenorphine using the opioids-related public health emergency.
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.
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.
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.
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.
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.
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.
On Jan. 27, AMCP, along with 76 other healthcare organizations, signed on to a consensus statement on health equity. In the statement, signatories recognize health inequity as a complex issue and reaffirm their commitment to take action within their organizations to reduce health inequities for the broader population.
On Dec. 15, AMCP joined 29 other pharmacy organizations in a letter calling on the Centers for Medicare and Medicaid Services to build upon the Public Readiness and Emergency Preparedness Act with guidance clarifying that states should reimburse clinical services provided by pharmacists at the same rates as other non-physician providers.
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."
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.
On August 4, the Department of Health and Human Services released a Notice of Proposed Rulemaking on Nondiscrimination in Health Programs and Activities. In response, AMCP submitted comments on September 29 which applaud the Department's goal to reinstate regulatory protections from discrimination in covered health programs and activities.
On August 19, AMCP joined a wide coalition of pharmacy organizations in calling on the Department of Health and Human Services to issue a PREP Act declaration that pharmacists, pharmacy students, and pharmacy technicians, as appropriate, can order and administer FDA authorized or approved monkeypox vaccines, testing, and therapeutics.
On June 7, AMCP joined a pharmacy stakeholder letter to the Department of Health and Human Services (HHS) requesting clarification that pharmacies will maintain personnel flexibilities granted under the PREP Act emergency declaration through October 1, 2024.
On June 9, AMCP submitted comments to CMS on the 2022 Healthcare Common Procedure Coding System (HCPCS) Public Meeting. AMCP applauds CMS's efforts to standardize coding and billing practices for prescription digital therapeutics (PDTs), and recommends that CMS create additional codes to cover the full range of PDTs.