Preserving, protecting and defending the health and safety interests of our increasingly diverse patient population — and bolstering the economic viability of independent LTC pharmacies serving their growing needs — are the foundational pillars of SCPC’s federal legislative and regulatory agenda. Moreover, fostering a strong and dynamic independent LTC pharmacy sector is integral to improving patient outcomes and optimizing Medicare savings, today and in the future. Operating in today’s volatile, unpredictable legislative and regulatory environment requires flexibility, foresight and tactical agility. These four overarching principles will guide us:
- Clinical efficacy, and achieving optimal patient outcomes
- Pricing transparency and marketplace equity
- Regulatory efficiency, effectiveness and fairness
- Policy solutions that anticipate and act upon future trends related to our long term and post-acute care patient populations
Pass Statutory Federal Definition of LTC Pharmacy into Law to Protect Seniors, Optimize Multiple Clinical Benefits
Existing federal regulatory requirements impose conflicting and confusing obligations on LTC pharmacies. This threatens patient care by disrupting essential medication management protocols, clinical services and care coordination activities needed to improve and optimize patient outcomes.
Modernizing regulatory oversight with a specific federal definition of LTC pharmacy – which must be passed into law by Congress — is long overdue. Creating a federal definition will alleviate vagaries and confusing overlap between CMS, EPA, FDA and other regulatory bodies. This will protect seniors all along the rapidly expanding care continuum — from institutional and community care settings all the way to the home.
Drug Pricing Reform Priority: Medicare Beneficiary Out of Pocket Costs Capped as Low as Possible
As Congress and the Administration work towards passage of a final drug pricing reform bill, SCPC will continue to support capping Medicare Part D beneficiaries’ out of pocket costs as low as possible.
Capping out-of-pocket costs — and ultimately passing a final bill with caps as low as possible — would make drugs more affordable for elderly patients, improve their overall ability to sustain their prescribed regimen, and, by doing so, improve their overall health.
Pass Legislation to Make Already Reported PBM Data Publicly Available
To better ensure CMS and consumers have access to drug pricing information relevant to seniors residing in long term care (LTC) facilities, SCPC specifies that the Senate Finance Committee-introduced Prescription Drug Pricing Reduction Act (PDPRA) and the Lower Cost, More Cures Act of 2019 (S. 3129/H.R. 19), introduced by Sen. Mike Crapo (R-ID) and Rep. Greg Walden (R-OR), respectively, should be amended to require disclosure of relevant PBM data.
Currently shielded from consumers and the public, SCPC believes sharing this data and increasing transparency is beneficial to seniors, consumers and the public-at-large. SCPC also wants the bills further improved by clarifying that PBMs and PDPs should also separately report data involving Medicare beneficiaries and other consumers served by an LTC pharmacy — separate from other retail pharmacy data.
- “Senior Care Pharmacy Coalition (SCPC) Suggests Two PBM Transparency Refinements to Senate Finance Committee Drug Pricing Bill“
- “To boost transparency, amend bills to require PBM disclosure data related to seniors residing in long-term care facilities“
- Senior Care Pharmacy Coalition (SCPC) – Comments on Transparency in Coverage, January 2020
Establish Independent, Third-Party Pharmacy Quality Metrics
SCPC supports the development of pharmacy quality metrics via stakeholder consensus and collaboration with independent third parties. This will help ensure LTC pharmacies rightly have the ability to develop metrics that accurately and specifically reflect outcomes specific to LTC patients.
Further, HHS should assure that pharmacy metrics used to evaluate PDP performance are independently developed and validated if used to evaluate performance of LTC pharmacies under Medicare Part D. It is essential that metrics provide accurate information about the quality of pharmacy services provided to LTC patients.
Impact Long Term Care at Home (LTC@Home) Legislative and Regulatory Agenda
SCPC must be engaged across our entire, growing care continuum — all the way to the home, where the marketplace itself is driving the policy discussion as well as the future reality of clinical services delivery. We must further ensure the existence of a federal payment platform that appropriately funds LTC pharmacy services in whichever setting they’re provided.
Developing substantive, bipartisan, data-validated ways to positively impact federal legislative and regulatory policy to optimize LTC pharmacies’ competitive foothold in the evolving LTC@Home space is an organizational priority.