Author: Tyrone Squires, MBA, CPBS

This author has written 1305 articles

Union takes to task pharmaceutical manufacturer on a $6,000,000 per year specialty drug

Click to read the entire letter to POTUS

On Monday, November 26, 2018, the Trump administration proposed a set of strategies to lower pharmaceutical costs in Medicare Part D. As set out in the proposed rule, the plan has three major new provisions:

1) Providing Part D plans with more flexibility to manage protected classes

2) Updating existing e-prescribing systems to make patients’ costs visible when a prescription is ordered

3) Requiring pharmacy price concessions for drugs at the point of sale

On the heels of this proposal, I want to share with you a letter written by Boilermakers National Health & Welfare Fund (BNF) to POTUS which clearly illustrates why the proposed changes are necessary. I am posting the letter in its entirety with permission from BNF’s COO, Lori Jasperson.

In short, BNF has one family on Strensiq, a new specialty drug manufactured by Alexion Pharmaceuticals, with a projected price tag of $6,000,000.00 per year! Rather than take that price lying down, BNF decided to get the CEO of Alexion on the phone.

In my hood, we have a euphemism for this sort of action “pressure bursts pipes” no pun intended Lori. Read the letter and the result of those phone conversations by clicking here.

Reference Pricing: “Gross” Invoice Cost for Popular Generic and Brand Prescription Drugs (Volume 247)

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.

The costs shared here are what the pharmacy actually pays; not AWP, MAC or WAC. The bottom line; payers must have access to actual acquisition costs or AAC. Apply this knowledge to hold PBMs accountable and lower plan expenditures for stakeholders.

 

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.

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.

4 Key Factors Employers Must Consider When Evaluating Specialty Pharmacy Performance

A PBMs performance should be measured by the sum of its parts, not the whole. Employers should work with PBMs to understand how its preferred specialty pharmacy compares with industry benchmarks, and determine where the incumbent is exceeding or falling short of those benchmarks.

Source: BCBS Prescription Drug Costs Trend Update Report

Employers must consider the following four key factors in their evaluation of specialty pharmacies:

1. Specialty drug spending at the patient, drug and therapeutic category levels. In this case, employers should compare the rebates passed through by non-fiduciary PBMs and those from fiduciary-model PBMs.

2. Clinical outcomes and the value realized from the specialty drug spend.

3. Savings from unnecessary or avoided hospital, clinic, and emergency room visits.

4. Patient and provider satisfaction.

Ensuring only high-performing specialty pharmacies in PBM pharmacy networks benefits both employers and patients, as a result of improved patient adherence and the elimination of wasteful Rx spending.

State Settles $500k Dispute with a Big Three Pharmacy Benefits Manager

Click to Learn How

The Attorney General’s Office and the Vermont Department of Human Resources have settled a dispute with the State’s pharmacy benefits manager for $503,500. The State’s pharmacy benefits manager, Express Scripts, oversees management of prescription benefits for the State’s employees and retirees.

Tyrone’s Commentary:

I want more than anyone that PBMs deliver radical transparency to their clients. I don’t, however, believe organizations should be able to clawback overpayments from non-fiduciary PBMs for a bad deal it willingly signed. So, it makes me wonder why did Express Scripts settle when for decades it has thumbed its nose at complaints about overpayments? Winning radical transparency from non-fiduciary PBMs boils down to two things; knowledge and grit. Occasionally, the threat of a lawsuit or moving business to a competitor doesn’t hurt.

The State will receive the settlement amount in increased guaranteed prescription rebates payable in 2019 for prescriptions purchased in 2018. The settlement resolves a dispute about charges paid by the State several years ago under a now-expired contract.

[Read More]

Reference Pricing: “Gross” Invoice Cost for Popular Generic and Brand Prescription Drugs (Volume 246)

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.

The costs shared here are what the pharmacy actually pays; not AWP, MAC or WAC. The bottom line; payers must have access to actual acquisition costs or AAC. Apply this knowledge to hold PBMs accountable and lower plan expenditures for stakeholders.


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 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.

Express Scripts announces “new” formulary that favors lower-cost generics

…I was under the impression PBMs already favored lower-cost generics?

Express Scripts announced last week a new “formulary,” or list of covered drugs, that will favor lower-cost generic versions of the drugs rather than expensive, branded versions. Now its clients, including both health insurers and employer plans, can choose between lists that include drugs with a high list price — and high rebate to PBMs like Express Scripts — or the new list with lower-price drugs but with little or no rebate.

Tyrone’s Commentary:

TransparentRx has favored lower-cost generics over higher cost brand drugs, regardless of rebates, for almost a decade! In fact, we’ve shunned potential business from employers who viewed rebates as “free” money and wanted to steer our formulary toward that end. It will be interesting to see if the conflicts of interests and misaligned incentives, some brokers and consultants benefit from, begin to dissipate in favor of putting the needs of members and employers first. It’s time we start measuring value across all stakeholders with radically transparent data and conversations. 

Under the current model, drug manufacturers set a list price for their medications and negotiate a rebate off that price with PBMs in exchange for having their medicines placed on a list of covered and preferred medicines. Experts say it’s not always clear who gets the rebate, but part of it goes to employers or insurance companies while PBMs also keep a percentage. This model leads to higher costs for patients as drugmakers increase list prices to offset the cost of rebates.

[Read More]

Reference Pricing: “Gross” Invoice Cost for Popular Generic and Brand Prescription Drugs (Volume 245)

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.

The costs shared here are what the pharmacy actually pays; not AWP, MAC or WAC. The bottom line; payers must have access to actual acquisition costs or AAC. Apply this knowledge to hold PBMs accountable and lower plan expenditures for stakeholders.

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 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.

Achievement is Significant But Comes with a Huge Price Tag: New Regulation Requires Regulatory Oversight of Pharmacy Benefit Managers (“PBMs”)

Click to Enlarge

This achievement is bittersweet so allow me to provide the back story. Approximately four years ago, we applied to the Nevada Division of Insurance, our home state, to become a continuing education service provider.

A primary benefit of being certified in our home state is reciprocity. This means approval by our home state would be recognized by every other state in the country without having to go through the full application process within those states. Reciprocity reduces cost and significantly reduces the administrative burden. We assumed getting approved as a CE (continuing education) provider in the same state for which we are domiciled was a no-brainer until it wasn’t!

Because the state of Nevada didn’t regulate PBMs, TransparentRx’s initial application to become a CE provider was not approved. Those of you familiar with these sorts of applications know that you can’t just try once and give up. You must push through and sometimes that requires educating or partnering with the entity who has the final say so.

It just didn’t make sense to us other states approved us who didn’t regulate PBMs so why Nevada. It turns out Nevada was just an anomaly. Consequently, we petitioned the Nevada Division of Insurance for two years and finally last week we were approved as a CE provider. As a result, our approval is now recognized by the remaining 49 states without having to go through the full application process with each individual state. Can I get an amen?

Imagine having to submit an application, renew each course and/or each instructor for all 50 states each having their own applications, deadlines, costs etc. This was a monumental task which has finally been lifted. I’m grateful but…

There is always a but isn’t there? The but in this case is that the state of Nevada is now going to regulate pharmacy benefit managers. Good, bad or indifferent I’ve always preferred a laissez-faire approach to policy when it comes to the free market.

Coincidentally, the state of California just passed Assembly Bill 315 which was written to secure more disclosure and transparency from PBMs. This is extremely significant legislation. Since California usually takes the lead on policy and regulation, expect more states to follow their lead.

Click here to view Assembly Bill 315 in its entirety.

Reference Pricing: “Gross” Invoice Cost for Popular Generic and Brand Prescription Drugs (Volume 244)

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.

The costs shared here are what the pharmacy actually pays; not AWP, MAC or WAC. The bottom line; payers must have access to actual acquisition costs or AAC. Apply this knowledge to hold PBMs accountable and lower plan expenditures for stakeholders.

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 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.

“Don’t Miss” Webinar: How to Slash PBM Service Costs, up to 50%, Without Changing Vendors or Benefit Levels

How many businesses do you know want to cut their revenues in half? That’s why traditional pharmacy benefit managers don’t offer radical transparency and instead opt for hidden cash flow opportunities such as rebate masking. Want to learn more?


Here is what some participants have said about the webinar.

“Thank you Tyrone. Nice job, good information.” David Stoots, AVP
“Thank you! Awesome presentation.” Mallory Nelson, PharmD
 
“Thank you Tyrone for this informative meeting.” David Wachtel, VP

“…Great presentation! I had our two partners on the presentation as well. Very informative.” Nolan Waterfall, Agent/Benefits Specialist

A snapshot of what you will learn during this 30 minute webinar:

  • Hidden cash flows in the PBM Industry such as formulary steering, rebate masking and differential pricing
  • How to calculate cost of pharmacy benefit manager services or CPBMS
  • Specialty pharmacy cost-containment strategies
  • The financial impact of actual acquisition cost (AAC) vs. maximum allowable cost (MAC)
  • Why mail-order and preferred pharmacy networks may not be the great deal you were sold
Sincerely,
TransparentRx
Tyrone D. Squires, MBA  
3960 Howard Hughes Pkwy., Suite 500  
Las Vegas, NV 89169  
866-499-1940 Ext. 201


P.S.  Yes, it’s recorded. I know you’re busy … so register now and we’ll send you the link to the session recording as soon as it’s ready.