On March 1, 2019, AMCP provided comments to CMS in response to its 2020 for Medicare Part D Call Letter. AMCP offered comments on the following sections of the notice; Part D Benefit Parameters for Non-Defined Standard Plans; Formulary Submissions; Medication Therapy Management (MTM); and Part D Mail Order Auto-Ship Modifications.
On January 31, 2019, HHS proposed sweeping changes to the current system for medication pricing and contracting by PBM companies in federal programs. This summary reviews OIG's proposal to eliminate the safe harbor protections for rebates that exist in the federal Anti-Kickback Statute (AKS) and replace these protections with proposed new safe harbors allowing for point-of-sale discounts to beneficiaries and for manufacturer-paid service fees to PBMs.
On January 30, 2019, CMS published an Advanced Notice of Methodological Changes for Calendar Year 2020 for Medicare Advantage Capitation Rates, Part C and Part D Payment Policies and 2020 Draft Call Letter. The summary outlines proposals in the draft Call Letter.
On January 25, 2019, AMCP provided comments to CMS in response to its proposed rule on lowering drug prices and reducing out-of-pocket expenses in the Medicare program. The letter outlines the proposal’s impact on providing plan flexibility to manage protected classes, prohibition against gag clauses in pharmacy contracts, E-Prescribing and the Part D Prescription Drug Program, Part D explanation of benefits, and Medicare Advantage and step therapy in Part B.
On January 25, 2019, AMCP provided comments to CMS in response to the proposed rule on Modernizing Part D and Medicare Advantage to Lower Drug Prices and Reduce Out-of-Pocket Expenses. AMCP offered comments on the following CMS proposals; Providing Plan Flexibility to Manage Protected Classes; Prohibition Against Gag Clauses in Pharmacy Contracts; E-Prescribing and the Part D Prescription Drug Program; Updating Part D E-Prescribing Standards; Part D Explanation of Benefits; and Medicare Advantage and Step Therapy for Part B Drugs.