Monthly Archives: October 2021

Just because a drug is approved by the FDA, does not mean it has proof of efficacy [Weekly Roundup]

 News and notes from around the interweb:

  • An attorney shares the warning signs of ‘self-serving’ PBMs. PBMs are designed to manage prescription drug benefits on the behalf of health insurers, saving both insurers and consumers money on prescription drugs. However, as the pharmaceutical industry has ballooned and drug prices have increased 33% since 2014, questions have been raised over whether PBMs are acting in the interest of their clients.
  • Strategies for Aligning and Integrating Infusion Services Across the Health System. Nancy Palamara, PharmD, the vice president for diagnostics and therapeutics at Holy Name Medical Center, in Teaneck, N.J., polled session attendees as to who at their institution has operational oversight of the outpatient infusion center and all of its staff. The most common response was a nurse manager (35%), followed by a nonclinical manager (15%), pharmacist (4%) and physician (2%); 31% of respondents said oversight was handled by a mix of those roles, while 13% did not know.
The Certified Pharmacy Benefits Specialist (CPBS) educational offering includes knowledge that is critical to effective management of the pharmacy and medical drug benefit. If you want to learn more, click here.

Reference Pricing: “Gross” Invoice Cost vs. AWP for Popular Generic and Brand Prescription Drugs (Volume 386)

This document is updated weekly, but why is it 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 health care reform.

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 acquisition costs then determine if a problem exists. When there is more than a 5% price differential for brand drugs or 25% (paid versus actual cost) for generic drugs we consider this a potential problem thus further investigation is warranted.

Multiple price differential discoveries mean 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.


Three surefire ways to know if your PBM is overcharging you

Pick anyone from HR, finance or procurement and they will tell you succinctly the pharmacy cost trend is not sustainable. Most have tried every trick in the book including increasing employee cost share, restricting access or reducing benefit levels. But, ask these same professionals how much money their PBM is making and you’ll likely get crickets. It is not uncommon for the non-fiduciary PBM’s take home to amount to more than the cost of the prescription drugs.

I’ll let the note Michael Critelli, former CEO at Pitney Bowes, sent to me address that point. “I am pleased that you wrote the particular essay I downloaded. Many corporate benefits departments do not understand that they are overmatched in negotiating with pharmacy benefit managers, as are the “independent consultants” who routinely advise them. The first step in being wise and insightful is admitting what we do not know, and you have humbled anyone who touches this field.” 


For those interested in improving their company’s pharmacy benefit management results and unafraid of unconventional concepts, here are three surefire ways to know if your PBM is overcharging you.

1) Contract definition for brand and generic drugs. Brand Drug means a prescription product identified as a “brand” by Acme PBM or its designee using indicators from reporting services such as First Databank or other third party reporting sources. If your definition for brand or generic drugs looks remotely close to the example above, then you are being overcharged.

2) Contract definition for rebates. The definition for rebates in your contract should not include any exclusions or limitations. Strike any language that reads similar to Rebates do not include administrative fees paid by Pharmaceutical Manufacturers, Rebates do not include purchase discounts paid by Pharmaceutical Manufacturers, or directly attributable to the utilization.

3) Low or no administrative fee. An artificially too low administrative fee is a dead giveaway for overpayments. This is especially true when the plan sponsor has no audit rights on pharmacy reimbursements, no ability to determine net costs through NDC claim level detail for rebates, or finally little input on benefit design beyond member cost share, for instance.

Managing the pharmacy benefit efficiently is no easy task. It requires quite a bit of time, effort and skill to do it right. Anyone with business training can look at a P&L statement and determine whether or not a company made a profit. However, understanding the story behind those numbers requires a certain set of skills only a certified public accountant can provide, for example. The same can be said for pharmacy benefits as it too requires a particular set of skills and values to achieve lowest net cost.

An attorney shares the warning signs of ‘self-serving’ PBMs [Weekly Roundup]

 News and notes from around the interweb:

  • An attorney shares the warning signs of ‘self-serving’ PBMs. PBMs are designed to manage prescription drug benefits on the behalf of health insurers, saving both insurers and consumers money on prescription drugs. However, as the pharmaceutical industry has ballooned and drug prices have increased 33% since 2014, questions have been raised over whether PBMs are acting in the interest of their clients.

The Certified Pharmacy Benefits Specialist (CPBS) educational offering includes knowledge that is critical to effective management of the pharmacy and medical drug benefit. If you want to learn more, click here.

Reference Pricing: “Gross” Invoice Cost vs. AWP for Popular Generic and Brand Prescription Drugs (Volume 385)

This document is updated weekly, but why is it 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 health care reform.

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 acquisition costs then determine if a problem exists. When there is more than a 5% price differential for brand drugs or 25% (paid versus actual cost) for generic drugs we consider this a potential problem thus further investigation is warranted.

Multiple price differential discoveries mean 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.

Self-funded employers have a corporate responsibility to understand MAC lists

PBMs with a traditional business model typically allow for price spread in exchange for reduced or eliminated administrative fees. It can generate a significant percentage of its revenue by retaining the spread from the MAC list. In some cases, this may be disclosed; however, plan sponsors are often not aware of how much revenue the traditional PBM retains. Auditing of this process is often very difficult.

With this method, the traditional model PBM uses an aggressive MAC price list to buy from their contracted pharmacies and a different, less aggressive list of prices when they sell to their clients. In essence, these PBMs buy low, and they sell high with their MAC price lists, marking up what they buy. The money derived from using multiple MAC lists goes into the pocket of the traditional PBM.

In contrast, a PBM with a radically transparent, pass-through business model does not keep the spread. Instead, this type of PBM uses one MAC list for all purposes: buying from the pharmacies and selling to the client, and then passing through the same drug cost, without markup, to the client. All discounts accrue directly to the benefit of the client (and member).

MAC prices are the upper limits that a plan will pay for generic drugs and brand drugs that have generic versions available (multi-source brands). Generic drugs often have a huge range of Average Wholesale Prices (AWPs), and the MAC prices are needed to reconcile the differences between an inflated AWP and the price the pharmacy actually pays.

Click to Learn More

No two MAC price lists are alike. In other words, every PBM tends to pick and choose products for their MAC lists, using different criteria to derive and apply prices to the lists. Common criteria for inclusion of products on MAC lists include:

  • It’s a balancing act. The PBM’s goal is to work on behalf of its clients and members, bringing the best value, without unduly creating unrest among pharmacies.
  • There are basically two ways the PBM can handle the MAC price list: 1) they can be self-serving and operate a MAC list to generate revenue for themselves or, 2) they can fully pass-through all MAC discounts directly to the client.

A radically transparent, pass-through PBM’s only revenue source is an administrative fee that is typically calculated on a per paid claim or per-member, per-month (PMPM) basis. Any gains in pricing negotiated with pharmacy networks or pharmaceutical manufacturers are passed directly on to the client, at the beginning and throughout the course of the contract.

Be careful, PBMs can be transparent and still keep a spread using their MAC lists. Generally, pass-through pricing means that the PBM passes the discounts, rebates, other revenues and actual costs charged by the pharmacy or paid by a pharmaceutical company (in the form of rebates) directly on to the plan sponsor. In actual use, it can have various definitions according to the understanding of the parties. 

The term “pass-through” must be carefully defined in the contract in every instance it is used since there is no industry standardized term. A PBM may tell you that it will be transparent and pass-through, however, when presented with strict terms, the PBM may not be willing to abide by those terms. In summary, “transparent” PBMs are not necessarily “transparent pass-through” PBMs. While it may seem like a trivial distinction, it really isn’t.

Average Specialty Drug Price Reached $84,442 in 2020, Rising More Than Three Times Faster Than the Prices of Other Goods and Services [Weekly Roundup]

 News and notes from around the interweb:

  • Increasing Patient Adherence to Oral Chemo. With more than 115 oral agents approved by the FDA to manage different types of cancer, oral oncolytics “have solidified their place in cancer treatment,” a pharmacist said at the virtual 2021 ASHP Specialty Pharmacy Conference.

The Certified Pharmacy Benefits Specialist (CPBS) educational offering includes knowledge that is critical to effective management of the pharmacy and medical drug benefit. If you want to learn more, click here.

Reference Pricing: “Gross” Invoice Cost vs. AWP for Popular Generic and Brand Prescription Drugs (Volume 384)

This document is updated weekly, but why is it 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 health care reform.

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 acquisition costs then determine if a problem exists. When there is more than a 5% price differential for brand drugs or 25% (paid versus actual cost) for generic drugs we consider this a potential problem thus further investigation is warranted.

Multiple price differential discoveries mean 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.

Kansas audited its $80 million prescription plan, but it’s still shrouded in mystery [Weekly Roundup]

 News and notes from around the interweb:

  • Kansas audited its $80 million CVS prescription plan, but it’s still shrouded in mystery. Kansas paid auditors $100,000 to dig into the more than $160 million it spent in 2018 and 2019 on prescription drugs for state employees, retirees and their families. But experts who follow the pharmaceutical industry say the resulting 16-page report doesn’t tell Kansas whether the health plan — or rather, the taxpayers and public employees who fund it — got a bargain or got gouged.
  • PBM Settles Two Pharmacy Benefit Probes for $71 Million. The settlements, announced on Thursday in statements from the attorneys general in Illinois and Arkansas, are related to claims the pharmacy benefit management business inflated drug costs. The company has resolved similar disputes with Ohio and Mississippi and has reserved $1.1 billion to cover the claims.

The Certified Pharmacy Benefits Specialist (CPBS) educational offering includes knowledge that is critical to effective management of the pharmacy and medical drug benefit. If you want to learn more, click here.