Comment Letters

Senior Care Pharmacy Coalition (SCPC), Citing Unique Nature of Elderly Patient Population, Makes Case To Include Statutory Definition of Long-Term Care Pharmacy in Draft Legislation…

RE: CMS Proposed Rule: Modernizing Part D and Medicare Advantage to Lower Drug Prices and Reduce Out-of-Pocket Expenses, CMS 4180-P, RIN 0938-AT92, 83 Fed. Reg. 62152…Read More.

The Senior Care Pharmacy Coalition appreciates the opportunity to comment on the Part D provisions of the Draft Call Letter titled, “Advance Notice of Methodological Changes for Calendar Year (CY) 2019 for Medicare Advantage (MA) Capitation Rates, Part C and Part D Payment Policies and 2019 Draft Call Letter.” The Draft Call Letter includes several proposals affecting beneficiary access to medications under the program and the ability of long-term care (LTC) pharmacies to dispense those medications and provide related consultative services…Read More

January 16, 2018 Via Electronic Submission The Honorable Seema Verma, M.P.H. Administrator Centers for Medicare & Medicaid Services Department of Health and Human Services Attn: CMS-4182-P 7500 Security Boulevard Baltimore, MD 21244 Dear Administrator Verma: The Senior Care Pharmacy Coalition (SCPC) appreciates the opportunity to comment on the proposed rule entitled “Medicare Program: Contract Year […]

2017 Year-End Focus on Drug Pricing by Senate HELP, House Energy and Commerce Committees Demonstrate Ongoing Saliency of Examining PBM Market Manipulation…Read More.

The Senior Care Pharmacy Coalition (“SCPC”), on behalf of the long term care (“LTC”) pharmacies it represents and the residents of LTC facilities whom those pharmacies serve, is writing to ask your help in reconciling a conflict between two of the agencies within your Department – the Food and Drug Administration (“FDA”) and the Center for Medicare and Medicaid Services (“CMS”) – related to packaging of prescription drugs in long term care (“LTC”) pharmacies…Read More

The Senior Care Pharmacy Coalition (“SCPC”) appreciates the opportunity to provide the following comments to the Center for Medicare and Medicaid Service’s (“CMS”) draft 2017 Part D Call Letter, dated February 19, 2016 (the “Call Letter”)….Read More

We support efforts to ensure proper handling of hazardous waste pharmaceuticals (HWP) in the long- term care (LTC) setting. Our members are committed to take all reasonable steps to ensure the safety of the LTC residents that we serve and to protect the environment…Read More

The Senior Care Pharmacy Coalition (“SCPC”) appreciates the opportunity to address the Center for Medicare and Medicaid Services (“CMS”) “Medicare and Medicaid Conditions of Participation for Long Term Care Facilities” Proposed Rule, 80 Fed. Reg. 42168 (July 16, 2015) (the “Proposed Rule”1). The SCPC is the national association representing independent long term care (“LTC”) pharmacies. […]