[Kreweoftruth] PhRMA: More public input, patient protections will improve DHH Medicaid plan

[kreweoftruth at kreweoftruth.net]

MorePublic Input, Clearly Defined Patient Protections and Increased TransparencyWill Improve Bayou Health Pharmacy Benefit, PhRMA Says


 
The Louisiana Department of Health and Hospitals (DHH) shouldallow for additional public comment on yet-to-be-disclosed changes to theMedicaid pharmacy program, says a July 9 letter to the DHH Secretary BruceGreenstein from representatives of the biopharmaceutical industry. The letter,sent in response to a request for public comment on the agency’s recentroll-out of a “concept paper” regarding the future of the Louisiana’s $950million pharmacy program, notes that “stakeholders have only been afforded anopportunity to comment on abstract concepts, without knowledge of actualimplications of proposed changes,” and recommends that DHH allow additionalpublic input prior to any submittal of new rules 



-- Click here to read the letter -- 


“We commend DHH’s recent listening tour.  However, had these changes been soughtin statute, the legislative process would have allowed lawmakers andstakeholders alike, including patients, doctors, pharmacists and manufacturers,to provide testimony and ask questions about the specifics of a newpolicy.  We are simply asking thatthe rulemaking be conducted in a similar manner,” said PhRMA Spokesman JeffTrewhitt.


The letter to Greenstein also urged DHH to clearly define inany draft rules clear protections of patient access to prescription medications, consistent care for patients with chronic conditions that arestabilized on a particular drug therapy, and the ability of physicians to havea reliable, convenient process to obtain medically necessary medicines fortheir patients without new bureaucratic stumbling blocks. The letter alsocalled on DHH to provide greater transparency in the new managed care model. 


The letter notes that over the last two years, the LouisianaLegislature has worked with patient advocates, providers and the industry toestablish clear rules regarding insurance coverage of prescription drugs, andasks DHH to maintain those protections for patients in any expansion of a BayouHealth Medicaid pharmacy benefit. 


“Patient organizations across the state have stronglysupported recent legislative efforts to improve access to medications in theirinsurance coverage. I hope DHH continues those protections for the Bayou Healthplans,” said Marseah Delatte, Executive Director of the Community VolunteersAssociation, referring to legislation passed in 2011 and 2012 that streamlinedapproval processes and created clear pathways for physicians to seek and obtainoverrides to insurance coverage denial of some medications.   


Senate Bill 231 (Act 318 of 2012), by Sens. Ed Murray, D-NewOrleans and Fred Mills, R-New Iberia, creates a standard format for paperwork aprescriber must complete when requesting coverage of certain medications forpatients.  Prior to its passage,Louisiana physicians were required to wade through more than 200 forms to seekcoverage for patients.  SB 154 (Act144 of 2011), also by Sen. Murray, provides a clear pathway for physicians tooverride a patient’s requirement to enter into an insurer’s step therapy or“fail first” protocol, which would require a patient to take an alternative,often less expensive drug, and fail on it before to being granted coverage fora medication that a physician prescribes.
 
“The step therapy reform and prior authorization standardizationbills, which received overwhelming bipartisan support from the Legislature andwere signed by Gov. Bobby Jindal, were an important part of creating a fair andlevel playing field between the medical needs of patients and the costconsiderations of insurers.  Ourcomments urge DHH to maintain that balance in the new Bayou Health pharmacybenefit,” said Trewhitt.
 
PhRMA’s letter notes that while utilizations of cost “managementtools” such as prior authorization or step therapy may lead to some initialsavings, those procedures, which disrupt the doctor-patient relationship, alsolead to higher overall health care costs since patients can be denied access tomore effective treatments. This causes decreased adherence to medication regimensand increased use of other, more expensive health services such as emergencyroom visits.
 
Noting that medicines “are often the most effective means oftreating chronic illness, and the use of Medicaid funds for pharmaceuticaltherapies can offset higher costs such as hospitalizations,” PhRMA alsoencourages DHH to develop rules that allow patients with chronic conditions whoare stabilized on a prescription drug therapy to maintain coverage of thatmedication for the length of time that the product is achieving results.
 
“A patient who can live a healthier, more productive life becauseof access to a particular medication should be covered as long as thatmedication is working, even if a Bayou Health contractor should change itsformulary from time to time,” said Trewhitt.
 
PhRMA’s letter also stressed that the development processfor preferred drug lists for managed care organizations “is notably lesstransparent than that of Louisiana’s current fee-for-service Medicaid program,where there are specific requirements for public involvement,” and called on theDHH to develop clear rules that required greater transparency in the program. 
 
PhRMA’s recommendations include the following:

Ensure that preferred drug lists (PDLs) provide a broadrange of therapeutic drug classes and coverage options for all disease states. 
Require efficient step-therapy and fail-first processes thatinclude time limits on their implementation when determined to be clinicallyineffective. 
Enable step-therapy and fail-first protocols to be overriddenor opted out of under certain circumstances in accordance with Act 144 of 2011(RS: 22:1053).
Require responses to prior authorization requests within 24hours in accordance with R.S. 46:153.3(B)(2)(a)(i).
Require prescription refill and renewal requests within settime frames. 
Require prescription refill and renew without seeking priorauthorization if such medicines are subsequently removed from PDLs and aredetermined to continue to be medically necessary. 
Require drugs generally prescribed for indications treatedon an ongoing basis by continuous or as-needed medications to be filled withoutprior authorization if determined to be medically necessary. 
Dispense and require pharmacist reimbursement for a minimum72-hour emergency drug supply in accordance with R.S. 46:153.3(B)(2)(a)(ii). 
Specify public meeting frequency and public inputrequirements for Pharmaceutical and Therapeutics committees and establishrequirements for development of preferred drug lists, e.g., druginclusion/exclusion. 
Require that managed care plans offer newly approved FDAdrugs until the plan’s P&T committee has an opportunity to review the drugfor inclusion or exclusion. Likewise, maintain current requirements in legacyMedicaid that provide for coverage of new medications. 
Require prior authorization denials to be reported to DHH inaggregate quarterly, and to the legislature annually. 
Require use of a uniform prior authorization form in accordancewith Act 318 of 2012 (R.S. 22:1006.1).

 

 

cheron brylski
the brylski company
3418 coliseum street
new orleans, louisiana 70115
cbrylski at aol.com
504.897.6110
504.460.1468 cell
504.897.0778 fax
www.brylskicompany.com

 
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