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]

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.

...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]

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.

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.

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.

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 See you Tuesday November 13 at 2 PM ET! 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.

One of the first questions I often get during a new consulting assignment centers around cost data. More specifically, analyzing the cost of one proposal against that of another PBM vendor. When this happens I know there could be some trouble ahead for our partnership. Where costs are concerned, I'm most concerned with whether or not rebates, discount rates and dispensing fees are competitive. It takes all of 30 minutes to compare these data points among 5 to 7 competing PBM vendors. Once I know pricing is competitive my attention turns to the contract. You see PBMs don't set prices they negotiate for better pricing which is different than setting prices. All bets are off if the PBM repackages directly via a mail-order pharmacy or indirectly through say a national chain of retail pharmacies. More about this later. During Bill Clinton's 1992 successful presidential campaign, James Carville coined the phrase "It's the economy, stupid!" For our purposes and stealing a page from James Carville, "It's the contract, stupid!" All kidding aside, the contract will determine what you ultimately pay so in a sense words matter more than numbers. Here are seven PBM contract pitfalls you should not ignore. 1. Begin procurement at least six months before the renewal date to put your company in the best position to drive a hard bargain. The first day of procurement starts when you've sent the RFI notification letter not when you're just talking about renewal. Don't wait too long before you begin procurement. Incumbent PBMs and other stakeholders love it when the process is rushed. The reasons should be obvious. 2. Presuming you have strong contract definitions, make sure rates and fees are in alignment with those definitions. The problem is 75% of buyers, from Fortune 500 companies to start-up, have bad language in their contracts. Just below is an example of bad contract language. Can you spot the problem areas? If you're a decision-maker and you can't, get some training or hire someone to help with managing your pharmacy benefit, seriously. Click to Enlarge 3. Don't allow the PBM to use an in-house definition for rebates, brand, generic or specialty drugs. The devil is in the details and non-fiduciary PBMs rely on wordplay to access hidden revenue streams. 4. During a RFP process, never select a winning vendor before contract terms have been agreed to by both parties. Believe it or not more than 50% of buyers make this mistake and it costs them radical transparency. 5. Always include market check language in your contract. 6. Don't permit the PBM to put a ceiling on penalties for failing to meet performance guarantees. One exception to the ceiling rule is when the financial penalty exceeds the amount of fees paid. Put 50-100% of PBM fees at risk, up to the amount of fees paid, when guarantees aren't met. 7. Your general counsel and CFO are likely unqualified to uncover hidden PBM cash flows even less so to measure the impact of clinical services. Get training…

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 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.

Breakdown of the sources of health care wasteful pending Most employers are not collecting or analyzing data to track unnecessary healthcare spending, even though they see waste as a problem, according to the survey from National Alliance of Healthcare Purchaser Coalitions. Healthcare is estimated to waste more than $750 billion annually, and respondents said they view this is a problem. More than half of them  (57 percent) said they believe up to 25 percent of treatments employees and dependents receive are unnecessary. The survey involved 126 U.S. employers in several industries, including manufacturing, education, financial services and healthcare. For the purposes of the survey, waste was defined as "procedures and treatments that are overused, have limited effectiveness, and/or are repetitive to tests and procedures that have already been conducted." Four findings: 1. A majority of survey respondents (59%) don’t collect and analyze data in order to track waste. 2. One-third of employers in the survery (34%) farm out that task to at least one vendor (such as a pharmacy benefits manager, a health plan, or a consultant). 3. Only 7% of those surveyed said their organization tracks waste internally. 4. Respondents cited medical imaging, specialty drugs, prescription medications and  clinical tests as the largest contributors to waste. Tyrone's Commentary: A critical component to eliminating wasteful Rx spending is a leadership-instilled culture of learning. A learning employer is stewarded by leadership committed to a culture of teamwork, collaboration and adaptability in support of continuous learning as a core aim.  In a learning culture the employer takes ownership and doesn't kick the can down the road. Complex PBM operations and processes are constantly refined through ongoing team training and skill building, systems analysis and information development, and creation of the feedback loops for continuous learning and system improvement.  [Read More]