Where We Stand Position Statements
The Where We Stand series represents AMCP's position statements on a wide range of issues impacting managed care pharmacy. AMCP's position statements are regularly reviewed and updated by the AMCP Board of Directors.
Our positions are presented in alphabetical order, below.
Any Willing Provider Legislation
AMCP opposes any willing provider/pharmacy legislation. AMCP supports the ability of managed care organizations to selectively contract with only those providers necessary to enable the organization to provide patients with adequate access to pharmacy services, and quality, cost-effective health care.
Appropriate Uses of Prescription Information by Managed Care Organizations
AMCP believes that prescription information, whether individually identifiable by patient or prescriber or aggregated without identifying specific individuals, should be available for use by managed care organizations.
Best Price Requirement of the Medicaid Drug Rebate Program
AMCP believes that to provide the greatest value to Americans who need prescription drugs, market forces must effectively ensure that manufacturers of similar drugs compete with one another to establish reasonable pricing levels and maintain consumer access to needed therapies.
Biosimilar Drug Therapies
AMCP supports an abbreviated licensure pathway for the approval of biosimilar biologic drug therapies by the U.S. Food and Drug Administration (FDA). Biological products play an increasingly important role in the country's health care system - both in terms of scientific improvements in the treatment of disease and increased drug costs.
Collaborative Drug Therapy Management
AMCP supports collaborative drug therapy management (CDTM) as formal partnership between a pharmacist and a prescriber that allows the pharmacist to manage a patient’s drug therapy. CDTM, also referred to as collaborative practice, allows pharmacist to use their unique skills and abilities to complement other types of care provided by collaborating professionals to optimize patient outcomes.
Comparative Effectiveness Research and Patient-Centered Outcomes Research
AMCP supports scientifically sound research that compares the effectiveness and value of prescription drugs, as well as research aimed at tailoring treatment options to individual patients’ needs.
AMCP believes that a health care delivery system that is based upon a competitive marketplace will provide greater value to patients and payers than a system that is one-size-fits-all that relies on centralized governmental controls and regulatory mandates.
Confidentiality and Protection of Medication Error Reporting
AMCP supports a medication error reporting system that encourages participation and provides confidentiality and protection of the information reported and the person(s) reporting. Additionally, this system should establish processes to detect errors, identify trends or patterns and encourage changes to the medication delivery process to reduce the potential for future errors.
Co-Payment Offset Programs
AMCP believes that manufacturers, philanthropic organizations, plan sponsors, managed care organizations, and retail pharmacies should have the common goal of improving patient access by making medications affordable. AMCP also recognizes that many patients today depend on high-cost specialty medications that rarely have therapeutic alternatives.
AMCP discourages the use of direct-to-consumer advertising that promotes specific prescription drug products, but supports ads that educate the public about disease symptoms and available treatment options.
AMCP supports the use of evidence-based formularies that enhance quality of pharmaceutical care while lowering medication costs. A drug formulary is a continually updated list of prescription medications which represent current clinical judgment of providers who are experts in the diagnosis and treatment of disease.
Fraud, Waste, and Abuse in Prescription Drug Benefits
Fraud, waste, and abuse are problems that plague almost every sector of health care in the United States. The Centers for Medicare and Medicaid Services (CMS) estimates that fraud, waste, and abuse cost taxpayers billions of dollars annually within Medicare and Medicaid.
Fraud, Waste and Abuse in the Medicare Part D Prescription Drug Benefit
AMCP is deeply concerned about reports of fraud, waste and abuse within the Medicare Part D prescription drug benefit. AMCP has been a vocal proponent of the program, which has provided much-needed prescription drug coverage to millions of Medicare beneficiaries, increasing their access to affordable prescription drugs.
AMCP encourages the use of generic drugs as safe, cost-effective alternatives to the equivalent brand-name products. Generic drugs are approved by the U.S. Food and Drug Administration (FDA). When a generic drug is used, patients and health care professionals can expect to see a clinical result and safety profile equal to that of the brand-name drug.
Government Mandated Pharmacy Benefits
AMCP believes managed care organizations (MCOs) and their clients, (e.g., individuals, employers, government), must be able to independently make decisions regarding health benefits in order to meet the medical needs of their patient populations.
Government Regulation of Prescription Drug Pricing
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.
Interchange of Narrow Therapeutic Index (NTI) Drugs
AMCP opposes legislation that restricts the appropriate generic substitution of narrow therapeutic index (NTI) drugs. A drug is commonly referred to as having a narrow therapeutic index when small variances in blood levels cause changes in the effectiveness or toxicity of that drug.
Mail Service Pharmacies
AMCP believes that managed care organizations (MCOs) must have the flexibility to use mail service delivery of prescription drugs as a component of their prescription drug benefit.
The Management of Opioids
AMCP supports opioid management initiatives that ensure appropriate patient access and treatment of uncontrolled pain, while limiting abuse and diversion of opioids and opioid potentiators.
Maximum Allowable Cost (MAC) Pricing
MAC pricing is a payment model contractually agreed to in the marketplace by all participants. It includes payers and pharmacies and ensures employers and consumers – those purchasing health insurance benefits – get the lowest possible price on generic drugs.
AMCP supports the concept of medication synchronization as one tool that may improve adherence.
Off-Label Use of Pharmaceuticals and Related Products
AMCP supports off-label use of FDA-approved pharmaceuticals and related products when medically appropriate, safe and necessary. AMCP opposed government-mandated coverage of specific pharmaceuticals and related products, whether for FDA-approved or off-label uses, which can fail to consider safe, effective and lower-cost alternatives.
Patient Care Services Provided by a Pharmacist
AMCP supports compensation for pharmacists providing direct patient care services. Prescription medications have become the primary option for the treatment of the vast majority of chronic conditions and pharmacists are uniquely qualified by virtue of their specialized training to serve as the medication expert within the patient care team.
AMCP supports protection of patient confidentiality and endorses the responsible use of patient identifiable medical and prescription drug information by authorized pharmacists, physicians, and other health care professionals.
Patient Rights and Responsibilities
AMCP recognizes and supports the concept that all patients (and their caregivers) should have certain healthcare rights that assure confidentiality of healthcare services, provide access to high quality healthcare, and allow access to information with which they may make informed decisions regarding their medication therapy and healthcare choices.
Pharmaceutical Manufacturer Rebates
AMCP believes in competitive marketplace solutions to lower costs for Americans and recognizes the critical need to address the rising cost of prescription medications. Rebates represent a way to negotiate drug discounts and constitute an important tool to control drug costs.
Population Medication Management Services Improve the Value of Patients' Treatment and Health Outcomes
Population Medication Management Services Improve the Value of Patients’ Treatment and Health Outcomes Patients today increasingly rely on medications as an important component of managing long-term chronic conditions, including cancer, diabetes, rheumatoid arthritis, and other disease states.
Preapproval Information Exchange (PIE)
AMCP supports systems and processes that allow for clinical and economic information to be shared between manufacturers and health care decision-makers proactively and in a timely manner prior to FDA approval. A proactive PIE system would expedite coverage and utilization management policies for emerging therapies, including those granted breakthrough designation, providing earlier access for appropriate patients.
Preferred Pharmacy Networks
AMCP supports the ability of health plans to offer preferred pharmacy networks for their enrollees as a way of providing additional options and cost savings without diminishing quality or patient access.
Prescription Drug Coverage
AMCP supports the inclusion of prescription drug coverage in all health care benefit programs, including those administered by government agencies. Appropriate access to and use of prescription medications promotes both patient well-being and and the efficient use of medical resources.
Prescription Drug Importation
AMCP has concerns with legislative and regulatory proposals that would allow the commercial importation of prescription drugs for sale in the United States.
Provider Status for Pharmacists
AMCP supports the recognition of pharmacists as providers under the Social Security Act. When pharmacists are recognized as important members of the health care team, patient outcomes improve, patients report higher rates of satisfaction and overall health care costs are reduced.
Regulation of the Prescription Drug Benefit
AMCP believes that government should encourage an environment in which pharmacists working within managed care organizations, including pharmaceutical benefit management companies, can continue to develop innovative and integrated strategies to manage prescription drug benefits for a given patient population.
AMCP supports the use of therapeutic interchange programs as part of a comprehensive approach to quality, cost-effective patient care. Therapeutic interchange is the practice of replacing, with the prescribing physician’s approval, a prescription medication originally prescribed for a patient with a chemically different medication.
Transparency Within Health Care
AMCP supports efforts to encourage transparency within health care. Transparency enables payers, providers, and patients to make informed decisions regarding health care choices, including decisions regarding the use of prescription drugs.
Use of Technology
AMCP supports the implementation and expanded use of health information technology (HIT), including electronic health records, electronic prescribing, electronic prior authorization, real-time benefit check, telehealth, remote patient monitoring, digital therapeutics and other technology advancements that promote efficient use of healthcare resources, improve quality and patient and provider satisfaction.
AMCP supports the use of frameworks as a resource for determining the value of pharmaceuticals and other health technologies when the frameworks are based on sound methods using good scientific evidence and economic models.