Pharmacy Invoice Prices (Actual) for Top Selling Generic and Brand Prescription Drugs

Why is this document important?  Healthcare marketers are aggressively pursuing new revenue streams to augment lower reimbursements provided under PPACA. Prescription drugs, particularly specialty, are key drivers in the growth strategies of PBMs, TPAs and MCOs pursuant to healthcare reform. The costs shared below are what our pharmacy actually pays; not AWP, MAC or WAC.  The bottom line; payers must have access to “reference pricing” then apply this knowledge to lower plan expenditures for stakeholders.

As of 12/19/2013 – Published Weekly on Thursdays

How to Determine if Your Company [or Client] is Overpaying
Step #1:  Obtain a price list for generic prescription drugs from your broker, TPA, ASO or PBM every month.

Step #2:  In addition, request an electronic copy of all your prescription transactions (claims) for the billing cycle which coincides with the date of your price list.

Step #3:  Compare approximately 10 to 20 prescription claims against the price list to confirm contract agreement.  It’s impractical to verify all claims, but 10 is a sample size large enough to extract some good assumptions.

Step #4:  Now take it one step further. Check what your organization has paid, for prescription drugs, against our pharmacy cost then determine if a problem exists. When there is a 5% or more price differential (paid versus actual cost) we consider this a problem.

 
Multiple price differential discoveries means that your organization or client is likely overpaying. REPEAT these steps once per month.
 
— Tip —
 
Always Include a semi-annual market check in your PBM contract language. Market checks provide each payer the ability, during the contract, to determine if better pricing is available in the marketplace compared to what the client is currently receiving. 

When better pricing is discovered the contract language should stipulate the client be indemnified. Do not allow the PBM to limit the market check language to a similar size client, benefit design and/or drug utilization.  In this case, the market check language is effectually meaningless.

Adviser or Broker – which standard is most beneficial to plan sponsors?

How is it that a plan sponsor, regardless of size, can sign a deal which doesn’t hold its PBM accountable to a client-comes-first standard of care? Let’s take a look at the two standards:

Brokers (non-fiduciary)

  • Must recommend “suitable” products, not necessarily best or least expensive
  • Earn commissions or other transaction-based fees
 
Advisers (fiduciary)

  • Must put clients interests before their own
  • Most charge a fixed fee or percentage
Here is the definition of Fiduciary from Wikipedia

A fiduciary duty is a legal and/or ethical relationship of confidence or trust between two or more parties. Typically, a fiduciary prudently takes care of money for another person. One party, for example a corporate trust company or the trust department of a bank, acts in a fiduciary capacity to the other one, who for example has funds entrusted to it for investment. 

 
In a fiduciary relationship, one person, in a position of vulnerability, justifiably vests confidence, good faith, reliance and trust in another whose aid, advice or protection is sought in some matter. In such a relation good conscience requires the fiduciary to act at all times for the sole and interest of the one who trusts.
 
A fiduciary is someone who has undertaken to act for and on behalf of another in a particular matter in circumstances which give rise to a relationship of trust and confidence. A fiduciary duty is the highest standard of care at either equity or law. A fiduciary is expected to be extremely loyal to the person to whom he owes the duty (the “principal”): he must not put his personal interests before the duty, and must not profit from his position as a fiduciary, unless the principal consents.

When a fiduciary duty is imposed, equity requires a different, arguably stricter, standard of behavior than the comparable tortious duty of care at common law. It is said the fiduciary has a duty not to be in a situation where personal interests and fiduciary duty conflict, a duty not to be in a situation where his fiduciary duty conflicts with another fiduciary duty, and a duty not to profit from his fiduciary position without knowledge and consent. 
 
A fiduciary ideally would not have a conflict of interest. It has been said that fiduciaries must conduct themselves “at a level higher than that trodden by the crowd” and that “[t]he distinguishing or overriding duty of a fiduciary is the obligation of undivided loyalty.
 
 
I don’t completely understand why all self-insured plan sponsors don’t require pharmacy benefits managers to contractually obligate themselves to a fiduciary role; managers are too busy to investigate further, the C-suite isn’t aware of the potential cost savings, or maybe no one cares enough to make a change – all excuses.  As healthcare costs continue to climb it is increasingly important for plan sponsors to hold themselves, brokers, consultants and PBMs more accountable.
I’ve spoken directly with hundreds of benefit personnel and am surprised by how little they actually know about pharmacy benefits. Brokers, consultants and plan sponsors must become experts in pharmacy benefit management. If you know little about a subject area, in which cash is exchanged, you will undoubtedly be taken advantage of and leave money on the table.
I have a friend who is very smart, but has a difficult time judging people and their intentions.  I’ve always told her don’t give money to anyone asking for “spare change.”  This past Christmas Eve we were leaving Kohl’s department store and a gentleman walked up to her, gas can in hand, and asked for money.  He had been standing near an automobile appearing to pour gasoline into the tank.  It’s Christmas Eve right?
No one would dare hustle her the day before Christmas, right?  I’m shaking my head, having seen this scam many times, certain she was going to give him a buck or two.  Low and behold as I’m loading gifts into the automobile she walks over and says, “it’s only a dollar.”  By the time we get into the vehicle she looks out and sees the poor man’s vehicle still there, but he had vanished.  It wasn’t his vehicle!
Now, I may have fallen for the same trick had it not been for a conversation I overheard by two “homeless” men.  I had just left a business meeting in downtown Detroit when I overheard a man say to another, “How much money did you make today?”  His reply, “I only made $80 and I almost got into a fight with a dude trying to take my spot next to the freeway.”  I know what he did to make money because I had seen him there before.  I thought he was really struggling but low and behold it was his job.
The point here is that companies are “hustled” out of their hard earned revenue by traditional PBMs with similar deceptions everyday.  As Ronald Reagan once said, “trust, but verify.”  In order to verify one must be well-informed and knowledgeable. Then once the knowledge is gained add an additional safety net by requiring your PBM to sign as a fiduciary.

Resource for Payers: Acquisition Cost (pharmacy invoice) for Popular Brand & Generic Prescription Drugs

Why is this document important?  Healthcare marketers are aggressively pursuing new revenue streams to augment lower reimbursements provided under PPACA. Prescription drugs, particularly specialty, are key drivers in the growth strategies of PBMs, TPAs and MCOs pursuant to healthcare reform. The costs shared below are what our pharmacy actually pays; not AWP, MAC or WAC.  The bottom line; payers must have access to “reference pricing” then apply this knowledge to lower plan expenditures for stakeholders.

As of 12/12/2013 – Published Weekly on Thursdays

How to Determine if Your Company [or Client] is Overpaying
Step #1:  Obtain a price list for generic prescription drugs from your broker, TPA, ASO or PBM every month.

Step #2:  In addition, request an electronic copy of all your prescription transactions (claims) for the billing cycle which coincides with the date of your price list.

Step #3:  Compare approximately 10 to 20 prescription claims against the price list to confirm contract agreement.  It’s impractical to verify all claims, but 10 is a sample size large enough to extract some good assumptions.

Step #4:  Now take it one step further. Check what your organization has paid, for prescription drugs, against our pharmacy cost then determine if a problem exists. When there is a 5% or more price differential (paid versus actual cost) we consider this a problem.

Multiple price differential discoveries means that your organization or client is likely overpaying. REPEAT these steps once per month.

Include a semi-annual market check in your PBM contract language. Market checks provide each payer the ability, during the contract, to see if better pricing is available in the marketplace compared to what the client is currently receiving. 

When better pricing is discovered the contract language should stipulate the client be indemnified. Do not allow the PBM to limit the market check language to a similar size client, benefit design and/or drug utilization.  In this case, the market check language is effectually meaningless.

Payers: Know Your Prescription Drug Opportunity Costs

I want to make this very clear – not all PBMs engage in deceptive practices. There is a relatively new model, fiduciary, some PBMs are embracing.  This essentially means that a fiduciary PBM has taken the position to forgo driving revenue from hidden cash flows and instead earns revenue from a single source, an administrative fee [per script or per member]. 

 
A fiduciary PBM model provides payers with the opportunity to know the actual or true cost of its pharmacy benefit plan.  While this new business model benefits both plan sponsors and their members, some traditional PBMs either can’t or won’t adopt the fiduciary model for all of its clients.  
 
Here are four deceptive practices traditional PBMs use to hide cash flows from their clients thereby significantly increasing the actual cost of the plan.

Excessive Mark-ups from Mail-order Prescriptions

It is not uncommon for some PBMs to mark-up mail-order medications as much as 500%! Why do you think traditional PBMs push so hard to move prescriptions to mail-order from retail?


A fiduciary PBM will not make an undisclosed profit from mail-order dispensed medications. Again, it will only charge its plan sponsor a flat administrative fee per claim unless some other arrangement has been agreed upon.  The savings are passed back to plan sponsor reducing actual plan costs. 


This is not to say that drugs dispensed via mail-order are a bad thing. In fact, mail-order can offer quite a bit of savings.  But you must be aware of the arbitrage opportunities for non-fiduciary pharmacy benefits managers and eliminate them.

 
Rebates  
 
There was a study conducted by the Pharmacy Benefit Management institute which concluded that 47% of a traditional PBM’s revenue is derived from manufacturer revenue.  Just think about this for a second.  It is the plan sponsor driving the business for which these revenues are earned so why should they be earmarked for the PBM?  
 
These monies shouldn’t be shared with a PBM, but instead passed back to the plan sponsor 100%. Hence, the fiduciary PBM business model.

Don’t be duped, there are many names traditional PBMs may use to hide rebate cash flows such as reimbursements or SG&A expenses.  It doesn’t matter; the plan sponsor is entitled too any money awarded by a manufacturer as a result of prescriptions dispensed from its plan member. For a rebate eligible prescription drug, rebates are typically $2.00 – $3.00 per prescription.
 
Differential Pricing or Contracting
 
A deceptive tactic that is very common yet too many payers are unaware of its detrimental cost. Here is how it works; let’s say that a PBMs billing terms to a plan sponsor are based on AWP or average wholesale price for a certain generic drug.  But, the reimbursement to the network pharmacy for dispensing this medication is based on MAC or maximum allowable cost. 

MAC is always lower than AWP thus leaving a difference in price or contracting.  The amount a plan sponsor is billed should be exactly the same amount a network pharmacy is reimbursed otherwise how can a plan effectively determine its actual pharmacy benefit costs. 
 
Spreads
 
A spread occurs when a plan sponsor is billed the “least favorable” or higher amount for a prescription drug that is reimbursed by the PBM to the network or mail-order pharmacy at a lower cost.  The difference or spread is retained by the PBM. This should never happen, but it does all too often.  In fact, there is information in the marketplace suggesting that the average spread for prescription drugs dispensed as part of a pharmacy benefit is as much as $15! 

Again, if you don’t know the spread even exists or its amount how can a CFO or benefits director possibly determine the actual cost of the plan? This begs the question, “how does this happen?”

A simple example is when a PBM has different MAC price lists for plan sponsors and pharmacies. These MAC lists may differ in the number of drugs listed and/or their respective prices.  A fiduciary PBM will not have any spreads and should contractually bound itself to such. 
 
To prevent this from happening to your organization always require full auditing rights, real-time access to MAC lists and claims data.  Then compare the amounts billed (not all claims but maybe 20 or so per month) to the price lists and you’re now in position to determine actual costs.
 
I’ve discussed here only a handful of the hidden cash flows some PBMs use to keep plan sponsors in the dark.  There are many more like effective network rates, repackaging, formulary steering and co-pay differential.  If your current PBM doesn’t provide full audit rights or access to all MAC price lists and you’re still willing to “cut the check” then don’t complain about rising healthcare cost.

“Actual” Acquisition Costs (what pharmacy pays) of Top Selling Generic and Brand Prescription Drugs: for Payers

Why is this document important?  Healthcare marketers are aggressively pursuing new revenue streams to augment lower reimbursements provided under PPACA. Prescription drugs, particularly specialty, are key drivers in the growth strategies of PBMs, TPAs and MCOs pursuant to healthcare reform. The costs shared below are what our pharmacy actually pays; not AWP, MAC or WAC.  The bottom line; payers must have access to “reference pricing” then apply this knowledge to lower plan expenditures for stakeholders.

As of 12/5/2013 – Published Weekly on Thursdays

How to Determine if Your Company [or Client] is Overpaying
Step #1:  Obtain a price list for generic prescription drugs from your broker, TPA, ASO or PBM every month.

Step #2:  In addition, request an electronic copy of all your prescription transactions (claims) for the billing cycle which coincides with the date of your price list.

Step #3:  Compare approximately 10 to 20 prescription claims against the price list to confirm contract agreement.  It’s impractical to verify all claims, but 10 is a sample size large enough to extract some good assumptions.

Step #4:  Now take it one step further. Check what your organization has paid, for prescription drugs, against our pharmacy cost then determine if a problem exists. When there is a 10% or more price differential (paid versus actual cost) we consider this a problem.

Multiple price differential discoveries means that your organization or client is likely overpaying. REPEAT these steps once per month.

Include a semi-annual market check in your PBM contract language. Market checks provide each payer the ability, during the contract, to see if better pricing is available in the marketplace compared to what the client is currently receiving. 

When better pricing is discovered the contract language should stipulate the client be indemnified. Do not allow the PBM to limit the market check language to a similar size client, benefit design and/or drug utilization.  In this case, the market check language is effectually meaningless.

Some Patients Need Help with Medication Adherence from Pharmacists

Former Surgeon General C. Everett Koop once remarked, “Drugs don’t work in patients who don’t take them.”

In the pharmacy realm, not taking prescribed medications, or not taking them correctly, is known as non-adherence. Unfortunately, a new study commissioned by the National Community Pharmacists Association (NCPA), titled “Medication in America: A National Report Card,” uncovered some troubling levels of non-adherence among some of the most frequent medication users in the United States.
The research, conducted by Langer Research Associates, found that Americans 40 and older with a chronic medical condition requiring prescription medication receive on average a C+ when it comes to taking their medications correctly. Additionally, one in seven adults who meet the same criteria—approximately 10 million people—receive an F.

The grades were based on an average of answers to questions on nine non-adherent behaviors: whether or not in the past 12 months patients failed to fill a prescription; neglected to have a prescription refilled; missed a dose; took a lower dose than prescribed; took a higher dose than prescribed; stopped a prescription early; took an old medication for a new problem without consulting a doctor; took someone else’s medicine; or forgot whether they’d taken a medication.

These findings show that there are opportunities for prescription drug plans and policymakers to increase the nation’s overall adherence grade. On a federal level, NCPA urges Congress to pass the Medication Therapy Management Empowerment Act (S. 557 in the U.S. Senate and H.R. 1024 in the U.S. House of Representatives) to expand medication therapy management (MTM) services to Medicare Part D beneficiaries. This would not cost the government a dime; previous MTM programs have been shown to lower overall costs as increased pharmacist engagement with patients has avoided costlier health care treatments and procedures.
Additionally, plan sponsors should examine their plan designs to ensure they are supporting activities that promote strong adherence such as allowing patients to choose a pharmacy that best suits their individual needs and allowing refill synchronization, which enables patients to have all of their medications refilled on the same day each month. Both of these activities facilitate a stronger patient-pharmacist relationship and promote safer medication use.

There is a vested interest for all to increase adherence rates in patients, and enacting the aforementioned changes will help to reach that goal. By implementing common-sense reforms, we can help improve the adherence grade. After all, when it comes to safe medication use, anything less than an “A” is unacceptable.
By B. Douglas Hoey, RPh, MBA

Hoey is CEO of the National Community Pharmacists Association. The research referred to was commissioned by NCPA as part of the association’s Pharmacists Advancing Medication Adherence (PAMA) initiative, which is sponsored by Pfizer, Merck, and Cardinal Health Foundation.

Prescription Drug Prices: 10 Definitions All Payers $hould Know

Acquisition Cost is defined as the invoice price to the pharmacy for a prescription drug dispensed to a patient, minus the amount of all discounts and other cost reductions attributable to such dispensed drug.

Average Manufacturer Price (AMP) is the average price paid to the manufacturer for the drug in the United States by wholesalers for drugs distributed to retail community pharmacies and by retail community pharmacies that purchase drugs directly from the manufacturer. The health reform law excludes payments and rebates or discounts provided to certain providers and payers from the calculation of AMP.  

In March of this year, the Affordable Care Act (ACA) again amended the legal definition of average manufacturer price (AMP). AMP uniquely serves to determine both a multiple source drug’s reimbursement amount and the rebate amounts for single source, innovator single source, and multiple source drugs within the Medicaid program. No other pricing metric serves this dual function. 

Average Sales Price (ASP) – In 2005, Medicare began to pay for most drugs using an entirely new methodology based on ASP rather than AWP. Unlike AWP and WAC, there is a specific method to calculate ASP set forth in the MMA and the Act. Section 1847A(c) of the Act, as amended by the MMA, defines ASP as a manufacturer’s unit sales of a drug to all purchasers in the United States in a calendar quarter divided by the total number of drug units sold by the manufacturer in that same quarter. 

The ASP is net of any price concessions such as volume, prompt pay, and cash discounts; free goods contingent on purchase requirements; chargebacks; and rebates other than those obtained through the Medicaid drug rebate program. Certain sales are exempt from the calculation of ASP, including sales at a nominal charge.

Average Wholesale Price (AWP) is not based on actual transactional, marketplace price data.  Despite its name and its sometime use as a price index, the published AWP is not an average of actual wholesale prices. It is not intended to represent, and cannot be assumed to reflect, actual transaction prices.  

A wholesaler or other direct purchaser from a pharmaceutical manufacturer may agree to sell its products to one or more of its customers at prices that on their face are effectively lower than the published AWP. 

AWP information does not reflect any such lower pricing that may be made available in actual purchase transactions through a variety of methods, including, but not limited to, purchase, prompt-pay or other discounts, volume or other rebates or credits, or a variety of other price reduction arrangements.

Direct Price (DP) is the price directly reported to AWP publishers by a manufacturer as the list price at which non-wholesalers and healthcare providers may purchase drug products from that manufacturer. These publishers generally do not receive a reported DP for drugs that are sold by a manufacturer exclusively through wholesalers, although in some cases both a DP and a WAC may be provided at the manufacturer’s discretion. 

DP does not represent an actual sales price in any single transaction or group of transactions between a manufacturer and a non-wholesaler or healthcare provider, as any manufacturer may agree to sell its products to one or more customers at a lower price through any number of methods, including, but not limited to, discounts, rebates, credits or other net price reduction arrangements.


Federal Supply Schedule (FSS) are prices paid to manufacturers by the VA, other federal agencies, and certain other entities, such as Indian tribal governments, are set by the Federal Supply Schedule (FSS). Under the Veterans Health Care Act of 1992, manufacturers must make drugs available to covered entities at the FSS price as a condition of eligibility for Medicaid reimbursement.  

FSS prices are negotiated with manufacturers by the VA.15 In general, the FSS price may be no higher than the lowest contractual price charged by the manufacturer to any non-federal purchaser under similar terms and conditions. In order to determine this price, manufacturers supply the VA with information on price discounts and rebates offered to different customers and the terms and conditions involved. 

Under certain conditions, the VA may accept an FSS price that is higher than the price offered to some non-federal customers. According to the GAO, average FSS prices are more than 50 percent below the non-federal average manufacturer’s price.

Ingredient Cost

  • BRAND INGREDIENT COSTS – the discount from the list price, also called the Average Wholesale Price or AWP. Typical discounts range from AWP-12% to AWP-15%. A PBM may contract with a retail pharmacy at AWP-15% and then offer you an average discount of AWP-12%, keeping the difference. This is called a “spread” or “differential pricing.” Each percentage point of withhold is worth approximately $0.60 per script.
  • GENERIC INGREDIENT COSTS – generic discounts are priced in one of two ways: (1) as an AWP discount or (2) at a Maximum Allowable Cost (MAC). There is usually a large gap between these pricing elements – about $6.40 per prescription. Ask your PBM to price out the top 50 generics used in the previous year, giving you both the list price and the discounted pricing (either MAC or AWP MAC) and disclose whether your MAC pricing is cost effective. Interestingly, PBM’s derive revenue from MAC programs by contracting with pharmacies at MAC pricing and charging you the AWP discount. This is another form of differential pricing.
Maximum Allowable Cost (MAC) list generally refers to a payer or PBM‐generated list of products that includes the upper limit or maximum amount that a plan will pay for generic drugs and brand name drugs that have generic versions available (multi‐source brands).  Essentially, no two MAC lists are alike and each PBM picks and chooses products for their MAC lists, using different criteria to derive and apply prices to the list.  

Some of the factors that PBMs consider to choose products for inclusion on a list are availability of the product in the marketplace, whether the product is obtainable from more than one manufacturer, how the product is rated by the FDA in relation to the innovator drug and price differences between the brand and generic products. However, there is no standardization in the industry as to the criteria for the inclusion of drugs on MAC lists or for the methodology as to how the maximum price is determined, changed or updated. 

Suggested Wholesale Price (SWP) is the price that a manufacturer suggests wholesalers charge when selling the manufacturer’s drug to the wholesaler’s customers, as reported by the manufacturer. The SWP does not necessarily represent the actual sales price used by a wholesaler in any specific transaction or group of transactions with its own customers. Wholesalers determine the actual prices at which they sell drug products to their respective customers, based on a variety of competitive, customer and market factors.
 

Wholesale Acquisition Cost (WAC) is the price directly reported to publishers, like Wolters Kluwer Health, by a manufacturer as the list price at which wholesalers may purchase drug products from that manufacturer.  WAC does not represent an actual sales price in any single transaction or group of transactions between a manufacturer and a wholesaler, as any manufacturer may agree to sell its products to one or more customers at a lower price through any number of methods, including, but not limited to, discounts, rebates, credits or other net price reduction arrangements.

Click here to register for: “How To Slash the Cost of Your PBM Service, up to 50%, Without Changing Providers or Employee Benefit Levels.”

“Actual” Acquisition Costs (what pharmacy pays) of Top Selling Generic and Brand Prescription Drugs: for Payers

Why is this document important?  Healthcare marketers are aggressively pursuing new revenue streams to augment lower reimbursements provided under PPACA. Prescription drugs, particularly specialty, are key drivers in the growth strategies of PBMs, TPAs and MCOs pursuant to healthcare reform. The costs shared below are what our pharmacy actually pays; not AWP, MAC or WAC.  The bottom line; payers must have access to “reference pricing” then apply this knowledge to lower plan expenditures for stakeholders.

As of 11/21/2013 – Published Weekly on Thursdays
How to Determine if Your Company [or Client] is Overpaying
Step #1:  Obtain a price list for generic prescription drugs from your broker, TPA, ASO or PBM every month.

Step #2:  In addition, request an electronic copy of all your prescription transactions (claims) for the billing cycle which coincides with the date of your price list.

Step #3:  Compare approximately 10 to 20 prescription claims against the price list to confirm contract agreement.  It’s impractical to verify all claims, but 10 is a sample size large enough to extract some good assumptions.

Step #4:  Now take it one step further. Check what your organization has paid, for prescription drugs, against our pharmacy cost then determine if a problem exists. When there is a 10% or more price differential (paid versus actual cost) we consider this a problem.

Multiple price differential discoveries means that your organization or client is likely overpaying. REPEAT these steps once per month.

Include a semi-annual market check in your PBM contract language. Market checks provide each payer the ability, during the contract, to see if better pricing is available in the marketplace compared to what the client is currently receiving. 

When better pricing is discovered the contract language should stipulate the client be indemnified. Do not allow the PBM to limit the market check language to a similar size client, benefit design and/or drug utilization.  In this case, the market check language is effectually meaningless.

Pharmacy Benefits: Eight Ways it May Unfold in 2014

Pharmacy Benefits Managers (PBMs) are offering more complex programs and adopting data-mining tools to improve outcomes — not necessarily financial — for stakeholders.  Payers and their agents, however, continue to use antiquated tactics to alleviate the pain [cost] associated with offering pharmacy benefits; cutting benefits and increasing member cost-share.  Better planning and tougher decisions are required to rein in rising costs.

I.  Generic Drug Price Increase

While most of the country is ecstatic about the “Patent Cliff” not many payers have considered the potential negative effect on relative prices for generic prescription drugs.  It only makes sense, as competition decreases and demand increases, prices will eventually follow suit.

Furthermore, traditional PBMs will lose valuable manufacturer revenue or rebates.  Some PBMs will undoubtedly look to make up the difference thus generic drug prices, your MAC prices, will be the first stop.

In the online marketing world the key to success, in my opinion, is a relentless focus on A/B split testing.  The same is true for payers; where those whom relentlessly monitor drug costs throughout the year, making changes on the fly, minimize expenditures.  

Those payers whom more or less sign the contract, cut the check and wait for the renewal period unknowingly pay for the private corporate jets!  Find a reliable source for reference pricing and relentlessly monitor costs.        

 
II.  Drug Formulary Tier Increase
 

Specialty drugs are the fastest growing segment in the pharmaceutical supply chain.  The most common cost-share tier among our plan sponsors is three-tier — generics, preferred brands, non- preferred brands. We are starting to see the emergence of innovative cost-share structures with five or more tiers, but it is unclear whether these will become standard practice. 

The co-pay differential between tiers, in our pharmacy, continues to widen.  The difference between tier one and tier two co-pays has increased to $21 (compared to $5 about seven years ago).

III.  Fewer Employers to Offer Retiree Prescription Drug Plans
 
The percentage of employers that plan to continue offering prescription drug plans to Medicare-eligible retirees has dropped dramatically in the past two years, according to a study released May 29 by Buck Consultants L.L.C.

Fifty-five percent of employers that now provide pharmacy benefits for Medicare-eligible retirees said they plan to continue offering the benefit, down from 75 percent in the New York-based consulting firm’s 2011 survey.

Courtesy of Forbes.com
Another 33 percent of employers said they were unsure if they would continue offering prescription benefits to Medicare retirees after 2014, a significant increase from the 19 percent who were unsure in the 2011 survey.

“Employers have options for controlling prescription drug costs for Medicare-eligible participants,” Paul Burns, an Atlanta-based principal at Buck Consultants, said in a statement.

“For example, since retiree drug subsidy payments are no longer tax-exempt and do not keep pace with rising drug costs, some employers are considering moving to an employer group waiver plan to take advantage of additional subsidies available as a result of the Patient Protection and Affordable Care Act,” he said.

IV.  Medication Therapy Management: Non-traditional Method to Alter Behavior

MTM is a distinct service or group of services which optimize therapeutic outcomes for individual patients. As of 2013, MTM is approved for provision to Medicare Part D enrollees who have multiple chronic conditions (with a maximum of three plan selected chronic conditions being the lower limit), are taking multiple Part D drugs, and are likely to incur annual drug costs that exceed $3,144.  All Medicare beneficiaries who meet the above criteria as defined by each plan are automatically eligible to receive MTM services unless they voluntarily opt-out.

On the other hand, the provision of MTM services to non-Medicare enrollees by commercial health plans is less defined. Each plan has the liberty to devise different eligibility requirements together with different MTM service component which makes cross-program comparisons in such a heterogeneous environment quite difficult.  

Supporters of MTM (professional pharmacy societies, policy experts, etc.) would like to show health decision makers that tracking and evaluating MTM services outputs using Current Procedural Terminology (CPT) codes (approved as Category I codes in 2008) that MTM services result in better health outcomes cost reductions and positive return on investment in patients that need better medication management.

V.  Health Exchanges; Private and Public By Tom Norton

Even though the specifics of how PBMs under Obamacare will operate are unknown, I was told by many that if you want to understand how this new Obamacare PBM market is likely to play out, you should look to other insurance markets for insight. 

In particular, they said, the PBM operations in the Medicare Part D marketplace and even more to the point, the Rx services being offered by PBMs in the new private health exchanges, will provide a sense of the PBM offerings to be provided in Obamacare.

Perhaps an even more important PBM real world example is what is going on right now in the private health exchange environment. This is because it closely resembles the insurance concept planned for Obamacare.

Over the past few months, several large companies (Walgreens, IBM, GE, and others) have announced that they are moving their employees out of “defined benefit” health insurance plans, and placing them into “defined contribution” programs. This will be accomplished by utilizing private health exchanges. What exactly are these exchanges?

Private health exchanges have several different models. Some provide “self insured” programs to provide healthcare to individuals, while most offer group health insurance to employers under “fully insured” programs. The objective of both is to reduce the cost of healthcare to the employer.

This approach differs from today’s “defined benefit” insurance plans in which the PBMs are frequently “carved out” of the general health benefit and stand alone as separate services. PBMs do save the insurer money in this environment, but it’s thought they could save more if they were “carved in” to the insurance offering.

 
VI.  Self-Insured vs. Fully-Insured

I have noticed a trend in the PBM industry where self-insured organizations like employers and unions are making the transition to all-cash programs. Although I’m unsure to all the reasons for the change, one thing is clear and that is at least part of the change is due to the uncertainty provided by PPACA. Payers want to have control and relinquishing it is a scary proposition.

VII.  Limited Pharmacy Networks
After cost-sharing, establishing pharmacy networks has been a popular approach to cost management. Limited pharmacy networks, not talked of much before 2010, are more of a consideration after the contract dispute between Walgreens and Express Scripts.  
 

Providing the broadest access to members may no longer trump the more favorable pricing of a narrowed network.  A large and growing supply of retail pharmacies makes the limited network approach possible.  

VIII.  Specialty Drugs

Payers continue to be challenged by rapidly rising prescription drug costs, particularly specialty drugs.  However, traditional [and some transparent] Pharmacy Benefit Managers offer the same elixir for controlling these costs as they did a decade ago: increase patient use of mail-order, use of preferred or narrow pharmacy networks, a formulary design which promotes preferred drugs, reduce patient co-share for better outcomes.

While the aforementioned tactics do assist in controlling costs, they’re standard practice and are not the aggressive measures necessary to help reduce or control spending.  Payers should hire fiduciary PBMs – those legally obligated to truly put clients and their members first; before shareholders and profitability.

“Actual” Acquisition Costs (what pharmacy pays) of Top Selling Generic and Brand Prescription Drugs: for Payers

Why is this document important?  Healthcare marketers are aggressively pursuing new revenue streams to augment lower reimbursements provided under PPACA. Prescription drugs, particularly specialty, are key drivers in the growth strategies of PBMs, TPAs and MCOs pursuant to healthcare reform. The costs shared below are what our pharmacy actually pays; not AWP, MAC or WAC.  The bottom line; payers must have access to “reference pricing” then apply this knowledge to lower plan expenditures for stakeholders.

As of 11/14/2013 – Published Weekly on Thursdays

How to Determine if Your Company [or Client] is Overpaying
Step #1:  Obtain a price list for generic prescription drugs from your broker, TPA, ASO or PBM every month.

Step #2:  In addition, request an electronic copy of all your prescription transactions (claims) for the billing cycle which coincides with the date of your price list.

Step #3:  Compare approximately 10 to 20 prescription claims against the price list to confirm contract agreement.  It’s impractical to verify all claims, but 10 is a sample size large enough to extract some good assumptions.

Step #4:  Now take it one step further. Check what your organization has paid, for prescription drugs, against our pharmacy cost then determine if a problem exists. When there is a 10% or more price differential (paid versus actual cost) we consider this a problem.

Multiple price differential discoveries means that your organization or client is likely overpaying. REPEAT these steps once per month.

Include a semi-annual market check in your PBM contract language. Market checks provide each payer the ability, during the contract, to see if better pricing is available in the marketplace compared to what the client is currently receiving. 

When better pricing is discovered the contract language should stipulate the client be indemnified. Do not allow the PBM to limit the market check language to a similar size client, benefit design and/or drug utilization.  In this case, the market check language is effectually meaningless.